SpaceX Consolidated

COMMENT submitted by Space Exploration Technologies Corp.

SpaceX Comments

2017-07-17

This document pretains to SAT-PDR-20161115-00120 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2016111500120_1248753

KELLEY DRYE & WARREN LLP A LIMITED LIABILITY PARTNERSHIP WASHINGTON HARBOUR, SUITE 400 NEW YORK, NY FACSIMILE LOS ANGELES, CA 3050 K STREET, NW (202) 342-8451 HOUSTON,TX WASHINGTON, DC 20007 www.kelleydrye.com A U S T I N . T X chicago.il (202) 342-8400 PARSIPPANY N J EDWARD A. YORKGITIS, JR. STAMFORD. CT DIRECT LINE:(202) 342-8540 BRUSSELS, BELGIUM EMAIL: CY0RKGITIS@KELLEYDRYE.COM AFFILIATE OFFICE MUMBAI, INDIA April 20, 2018 By ECFS Marlene Dortch, Secretary Federal Communications Commission 445 12“’ Street, SW Washington, DC 20554 Re: Elefante Group Notice of Oral Ex Parte Presentation; GN Docket Nos. 17-183.14-177. IB Docket Nos. 17-95. WT Docket No. 10-112 and File No. SAT-LOA-20161115-00117 Dear Ms. Dortch: On April 18, 2018, CMstopher DeMarche of Elefante Group, Edward A. Yorkgitis, Jr., of Kelley Drye & Warren LLP, on behalf of Elefante Group, Inc. (“Elefante Group”), and Jennifer Warren, Scott Kotler, and Dr. Michael Hieks, of Lockheed Martin Corporation (“Lockheed Martin”) (colleetively, the “Representatives”) met with Charles Mathias, Blaise Scinto, Linda Chang, Charles Oliver, Janet Young, Tim Hilfiger (on the telephone), Tim Maguire (on the telephone) and Meaghan Ryan of the Wireless Telecommunications Bureau (“WTB”) to discuss Elefante Group’s plans to deploy persistent stratospheric-based communications and infrastructure and to file a petition for rulemaking to seeking a regulatory framework for the operation and licensing of the Stratospheric-Based Communications Services (“SBCS”) of Elefante Group and other operators. In the meeting, Mr. DeMarche laid out the progress Elefante Group is making, working closely with Loekheed Martin on stratospherie airship and eommunications payload technologies, in design, development, collaboration, and marketing efforts to enable deployment of its systems in the next several years. Elefante Group’s offering of SBCS will support high capacity, extremely speetrally effieient, fixed communieations operating compatibly with other incumbent users in the same spectrum. Those offerings will inelude 5G and 4G marketwide backhaul, enterprise WAN, and fixed wireless access, on a wholesale basis. Elefante Group’s stratospheric systems will also support integrated loT and eommunications capabilities for a variety of potential applieations.

KELLEY DRYE & WARREN LLP Marlene Dortch April 20, 2018 Page Two Elefante Group Stratospheric Platform Stations (“STRAPS”) are being designed to deliver 1 Tbps broadband infrastructure in each direction to User Terminals (“UTs”) within a nominally 70 km radius footprint. By offering such capacity that can be rapidly deployed and upgraded in urban as well as rural areas, Elefante Group will provide capabilities that will be instrumental to achieving many Commission objectives, such as winning the race to 5G and what follows, closing the Digital Divide, supporting reliable communications during and after major weather events and natural disasters, and creating thousands of new American jobs. Elefante Group encourages the Commission to take prudent action now that gives the SBCS - which represents new and irmovative technologies and allows for novel services warranting treatment under Section 7 of the Communications Act -- access to adequate spectrum. In so doing, the Commission will ensure that this country’s next generations of networks that roll out in the coming years will be able to exploit the complementary advantages offered by persistent stratospheric-based communications which are missing from other delivery solutions. A copy of the written presentation materials used in the meeting is attached hereto (the “Attachmenf’).^ Dr. Hicks reviewed the spectrum needs required to meet Elefante Group’s performance requirements of the planned SBCS systems and compatibility requirements to operate with incumbent systems. After considerable work over the past year examining a number of spectrum bands, Elefante Group and Lockheed Martin have determined that the 21.5-24.0 and 25.25-27.5 GHz bands present the most suitable candidates for SBCS, specifically for communications between the UTs and the STRAPS. (The 71-76 and 81-86 GHz bands are where Elefante Group plans to deploy fixed feeder links between STRAPS and terrestrial network facilities.) Dr. Hicks reviewed the considerable number of compatibility analyses that Elefante Group has undertaken in recent months to support the proposed candidate bands. To rigorously consider the prospects for compatible operations while meeting Elefante Group’s performance requirements, the Representatives explained that the analyses were undertaken from the starting point of assuming worst case conditions before, if even necessary, moving to consider statistical, risk-based assessments. Elefante Group and Lockheed Martin were pleased to report that, by designing compatibility from the outset into the Elefante Group system, the study results have been extremely positive that deployments can occur practicably with minimal to no impact on current incumbent operations while allowing such incumbent operations to grow and expand even as Elefante Group is deploying its networks. Dr. Hicks focused specific attention on 1 A minor correction in the Attachment has been made to the second-to-last bullet on slide two to conform to the compatibility studies actually reviewed in the slides, namely compatibility between different SBCS systems and between SBCS and Fixed Service systems (rather than Inter-Satellite Service links).

KELLEY DRYE & WARREN LLP Marlene Dortch April 20, 2018 Page Three analyses undertaken to demonstrate the anticipated compatibility, following coordination, among multiple non-exclusive SBCS deployments in the same geographic areas in eommon spectrum. He also explained the compatibility with existing fixed serviees in the 21.5-23.6 GHz range. The Representatives explained that the regulatory framework that Elefante Group envisions, and Loekheed Martin’s analyses support, will be derived from the eoordination that occurs among fixed links today. Further, traditional fixed services would be able to continue to deploy, following coordination, in the presence of SBCS system fixed UT links mueh as they do now in the presence of other fixed links. The Representatives also explained that IMT services would introduce special challenges were they to try to share compatibly with SBCS deployments, not to mention diffieulties IMT would have sharing spectrum with other incumbent users of the bands. Elefante Group Representatives underseored that, in eontrast, Elefante Group is offering to do something quite uncommon - introduce a high capacity service that will be essential for full deployment of this country’s next generation networks that is highly spectrum efficient (-Sbps/Hz and reuse of speetrum ~130 times by one STRAPS deployment), in a highly compatible fashion within encumbered spectrum without seeking to have any of the incumbents leave the band or be prevented from future growth. The Representatives explained that they are in the midst of meeting with incumbent stakeholders in the candidate bands, both non-Federal and Federal to share their compatibility studies. Elefante Group discussed its preparations to file a petition for rulemaking in the coming weeks to facilitate the deployment of the SBCS as a co-primary Fixed service, outlining the basic elements of the petition as set forth in the Attachment. The seope of the Petition will include both SBCS user links between UTs and STRAPS in the 21.5-24.0 and 25.25-27.5 GHz bands and feeder links in the 71-76 and 81-86 GHz bands. Where Fixed allocations do not already exist, Elefante Group will be seeking changes to the United States Table of Alloeations. Elefante Group advocates a regulatory framework that would set technical parameters complementary to and consistent with the goals of compatibility with existing types of operations in the subject bands, including compatibility among diverse types of SBCS deployments. In locations where compatibility may not be achieved solely through adherence to the technical parameters for SBCS, the proposed framework would eall for service-area STRAPS and site-specific UT coordination before deployment. Licensing of SBCS should be non-exclusive and on a rolling basis, combined with coordination where required and registration requirements as deployments of STRAPS and UTs oeeur so that other users of the band - both SBCS operators and ineumbent operators - will be able to coordinate and deploy additional facilities in these non-exclusive spectrum bands.

KELLEY DRYE & WARREN LLP Marlene Dortch April 20, 2018 Page Four Pursuant to Section 1.1206(b) of the Commission’s rules, this letter is being filed electronically. Respectfully submitted. Edward A. Yorkgitis, M Kelley Drye & Warren(LIJ^'' 3050 K Street, NW, Suite 400 Washington, DC 20007 (202) 342-8400 Counsel to Elefante Group, Inc. cc; Charles Mathias Blaise Scinto Linda Chang Charles Oliver Janet Young Tim Hilfiger (on the telephone) Tim Maguire (on the telephone) Meaghan Ryan

Elefante Group & Lockheed Martin Stratospheric Platform Communications 18 April 2018 Meeting with FCC Wireless Telecommunications Bureau 1

Agenda • Elefante Group’s Vision and Basic Business Plan • Basic Characteristics of Elefante Group Airship-Based Operations, Including Spectral Efficiency and Designs to Operate Compatibly with Incumbent Services • Spectrum Requirements of the Platforms and Terminals and Identify Primary Candidate Bands That Satisfy Performance Requirements and Support Compatible Operations • Compatibility Analyses Concerning Sharing with Incumbent Fixed Services and Other Stratospheric Operations and Interference Mitigation Where Required • Overview of Planned FCC Petition for Rulemaking for Stratospheric-Based Communication Services (SBCS) This presentation was prepared specifically for use in discussions with FCC in connection with Elefante Group and Lockheed Martin positions in present and potential future regulatory proceedings and is not to be used or relied upon for any other purpose. 2

Overview of Vision and Business Plan • Elefante Group aspires to be the world leader in transformative persistent stratospheric-based communications and IoT-enabling solutions • Elefante Group, working closely with Lockheed Martin on the technology, seeks to be the first company to bring new and innovative stratospheric solutions to market • Elefante Group will deploy a broadband infrastructure that supports 1 Tbps (both directions) wholesale fixed communications • 4G/5G Backhaul • Enterprise WAN • Residential Broadband • Sensor & IoT 3

EG Airship Systems Will Advance Multiple National Objectives • Significant investment in high speed broadband infrastructure developed in the USA • Capability to deploy innovative broadband solutions in both urban and rural areas to help close the Digital Divide • Enable densification of 4G, 5G and IoT with greater flexibility and lower cost • Maximizes spectral utilization with significant frequency reuse and other advanced techniques • Systems architecture optimized for deriving additional uses in encumbered spectrum while operating compatibly with existing services • Enablement of continuous market-wide technology upgrades with modular payloads in multiple bands • Supporting uninterrupted communications during and after major storms and natural disasters and facilitating rapid restoration for public safety and disaster relief • Will create thousands of US jobs in engineering, construction, and operations 4

Why a Stratospheric Airship as a Communications Platform? Unmanned Stratospheric Platform Stations (STRAPS) in development by EG/LM: • Stable-platform at nominally fixed altitude of @ 65kft (19.8 km) • Ensures low latency communications (less than 5ms) • IoT and high-resolution sensing • Above congested airspace and most weather systems • Nominal coverage of 70 km radius – ~15,400 km2 per platform • Possess large payload capability (1000+ kg, 10+ kW power) • Provide substantial capacity and rapid deployment in both urban and rural areas • Fully recoverable and serviceable and with upgradable payloads • Utilize hybrid (solar-based and fuel cell) power/propulsion to support maintain nominally fixed location • Ultra-long mission (> 6 mo. on avg.) on station with 10-15 year life • Low operating, maintenance, and overall lifecycle costs 5

Why fly at 65,000 ft? 90th% Wind Spe e d Isr ael Com par iso n of 95th% M onthly Win ds 100 110 90 Propulsion power 100 80 proportional to 90 cube of windspeed 80 70 Windspeed (knots) Altitude (kft) 60 Lowest wind speed 70 60 50 50 40 40 30 50 kft 30 20 55 kft 20 60 kft 10 65 kft 10 70 kft 0 0 20 40 60 80 100 0 1 2 3 4 5 6 7 8 9 10 11 12 Wind Speed (knots) Month Typical year-round wind speed profile Comparison of the 95th% Monthly Winds in a Northern Hemisphere in the Northern Hemisphere Location as a Function of Altitude Airship: ~65 kft (19.8 km) is the optimum altitude for most locations of interest based on wind speeds and airship payload-carrying capability, and above the weather Comm Payload: Large potential service area, low latency, low free space path loss permitting high spectral efficiency waveforms 6

Communications Architecture • User Links - Access and transport/backhaul to customers • Feeder Links – Customer to global network / datacenter connections • Cross Links – Inter-platform communication links • Command and Control (C2) Links – Commercially available satellite, in-band, and terrestrial control links depending on phase of airship operations Cross Links (RF or Free Space Optics) User Links 21.5-24 GHz and 25.25-27.5 GHz Feeder Links 71-76 GHz 81-86 GHz Feeder Links RLOS C2 5030-5091 MHz Gateway Gateway 7

Spectrum Requirements EG reference band plan designed to maximize throughput for an entirely new service while flexibly using spectrum to remain compatible with all existing services • User Links: Between Platform and Terminals • To satisfy performance requirements of 1 Tbps in each direction, operate compatibly with incumbent services, and allow multiple stratospheric solutions, EG and LM have determined the need for 4.75 GHz total spectrum • EG reference band plan uses 4x 450 MHz channels in each direction • 1.15 GHz additional for protections of incumbent services (alternate channels), flexibility for alternate implementations, guard bands preventing adjacent band and self-interference • Highly efficient spectrum reuse ( > 130 times per platform) and spectral efficiency ( > 4 bps/Hz) minimizes spectrum required • Gateway Links: Platform to Terrestrial Services • Platform gateway links will be in the 71-76 and 81-86 GHz bands, reusing the 10 GHz multiple times per platform. 8

U.S. Table of Frequency Allocations and Planned Frequency Bands EESS (passive) 21.2-21.4 NASA Federal Table Non-Federal Table Intended Use Federal Table Non-Federal Table Intended Use 21.4-22 21.5-22 GHz ONLY 25.25-25.5 25.25-25.5 CPE Downlink/ Uplink FIXED CPE Uplink / Downlink FIXED Inter-satellite 5.536 MOBILE INTER-SATELLITE 5.536 NASA Standard frequency and time signal-satellite (Earth-to-space) 22-22.21 CPE Uplink / Downlink MOBILE FIXED Standard frequency and time MOBILE except aeronautical mobile signal-satellite (Earth-to-space) 25.5-27 25.5-27 CPE Downlink/ Uplink US342 EARTH EXPLORATION- NASA SPACE RESEARCH 22.21-22.5 CPE Uplink / Downlink SATELLITE (space-to-Earth) (space-to-Earth) EARTH EXPLORATION-SATELLITE (passive) NASA, NOAA FIXED NOAA Inter-satellite 5.536 FIXED INTER-SATELLITE 5.536 NASA Standard frequency and time MOBILE except aeronautical mobile MOBILE DOD signal-satellite (Earth-to-space) RADIO ASTRONOMY NSF SPACE RESEARCH SPACE RESEARCH (passive) NASA (space-to-Earth) NASA US342 US532 Standard frequency and time signal-satellite (Earth-to-space) 22.5-22.55 CPE Uplink / Downlink FIXED 5.536A US258 5.536A US258 MOBILE 27-27.5 27-27.5 CPE Downlink/ Uplink US211 FIXED Inter-satellite 5.536 22.55-23.15 CPE Uplink / Downlink INTER-SATELLITE 5.536 NASA FIXED MOBILE DOD INTER-SATELLITE US145 US278 Iridium, Audacy MOBILE SPACE RESEARCH (Earth-to-space) 5.532A DOD • Elefante Group and Lockheed Martin US342 NSF undertaking studies of compatibility with non- 23.15-23.55 FIXED CPE Uplink / Downlink Federal fixed and ISS services INTER-SATELLITE US145 US278 MOBILE Iridium, Audacy DOD • Services from four federal agencies also 23.55-23.6 FIXED CPE Uplink / Downlink identified for compatibility analysis and pre- MOBILE 23.6-24 CPE Uplink / Downlink filing discussion EARTH EXPLORATION-SATELLITE (passive) RADIO ASTRONOMY US74 NASA NSF • We are seeking information on any additional SPACE RESEARCH (passive) US246 NASA federal or non-federal uses not identified 9

U.S. Table of Frequency Allocations and Planned Frequency Bands Federal Table Non-Federal Table Intended Use 71-74 (Gateway Downlink) • Elefante Group and Lockheed Martin FIXED FIXED-SATELLITE (space-to-Earth) undertaking studies of compatibility MOBILE MOBILE-SATELLITE (space-to-Earth) with non-Federal fixed services US389 • No Federal Agency uses currently 74-76 FIXED 74-76 FIXED (Gateway Downlink) identified for compatibility analysis FIXED-SATELLITE (space-to-Earth) MOBILE FIXED-SATELLITE (space-to- Earth) with Elefante Group gateways Space research (space-to-Earth) MOBILE • We are seeking information on any BROADCASTING BROADCASTING-SATELLITE federal uses not identified Space research (space-to- US389 Earth) US389 … 81-84 (Gateway Uplink) FIXED FIXED-SATELLITE (Earth-to-space) US297 MOBILE MOBILE-SATELLITE (Earth-to-space) RADIO ASTRONOMY Space research (space-to-Earth) US161 US342 US389 84-86 (Gateway Uplink) FIXED FIXED-SATELLITE (Earth-to-space) MOBILE RADIO ASTRONOMY US161 US342 US389 10

Compatibility Analysis Summary – Non-Federal EG Plan to Proposed Org Other Service Other Link STRAP Link Mitigate Study Results STRAP Band Interference FWCC FS P-P 25.25-27.5 User DL Not Required Airship transmission managed below satellite PFD limits per 25.208 (c) FWCC FS P-P 21.5-24.0 User DL Not Required Airship transmission managed below satellite PFD limits per 25.208 (c) Compatibility Analysis performed for each geographic area; limited site-specific 25.25-27.5 User UL Yes coordination may be needed when UTs located in very close proximity to existing co- FWCC FS P-P channel FS sites Compatibility Analysis performed for each geographic area; limited site-specific 21.5-24.0 User UL Yes coordination may be needed when UTs located in very close proximity to existing co- FWCC FS P-P channel FS sites FCC FS-SBCS User DL 25.25-27.5 User DL Not Required Adjacent SBCS service areas can overlap significantly – not mutually exclusive FCC FS-SBCS User UL 21.5-24.0 User UL Not Required Adjacent SBCS service areas can overlap significantly – not mutually exclusive Iridium ISS LEO->LEO 21.5-24.0 User UL Not Required Protection Criteria met under all conditions Audacy ISS MEO->LEO 21.5-24.0 User UL Not Required Anticipate Protection Criteria met (pending analysis with Audacy receive characteristics) 11

Compatibility Analysis Summary - Federal EG Plan to Proposed Org Other Service Other Link STRAP Link Mitigate Study Results STRAP Band Interference DOD MS Aero-> Ground 25.25-27.5 User DL Not Required Minimal likelihood of interference DOD MS Ground->Aero 21.5-24.0 User DL Not Required Minimal likelihood of interference DOD MS Aero->Ground 25.25-27.5 User UL Not Required Minimal likelihood of interference DOD MS Ground->Aero 21.5-24.0 User UL Yes Coordination/cooperation when <150 km of separation NASA ISS (DRS RTN) NGSO->GSO 25.25-27.5 User DL Not Required Protection Criteria met under all conditions NASA ISS (DRS FWD) GSO->NGSO 21.5-24.0 User DL Not Required Protection Criteria met under all conditions NASA ISS (DRS RTN) NGSO->GSO 25.25-27.5 User UL Not Required Protection Criteria met under all conditions NASA ISS (DRS FWD) GSO->NGSO 21.5-24.0 User UL Not Required Protection Criteria met under all conditions NASA EESS GSO->ES 25.25-27.5 User DL Yes Airship can be placed to avoid interference assuming basic mission info available NASA EESS GSO->ES 25.25-27.5 User UL Yes UTs placed relative to ES to avoid interference assuming basic mission info available NASA EESS NGSO->ES 25.25-27.5 User DL Yes Airship can be placed to avoid interference assuming basic mission info available NASA EESS NGSO->ES 25.25-27.5 User UL Yes UTs placed relative to ES to avoid interference assuming basic mission info available NASA SRS Space->ES 25.25-27.5 User DL Yes Airship can be placed to avoid interference assuming basic mission info available NASA SRS Space->ES 25.25-27.5 User UL Yes UTs placed relative to ES to avoid interference assuming basic mission info available NASA EESS Passive sensors 21.5-24.0 User UL Not Required Determined proposed isolation criteria for 21.2-21.4, 22.21-22.5, 23.6-24 GHz NSF RAS RAS passive 25.25-27.5 User DL Not Required Determined proposed isolation criteria for 23.6-24 GHz adjacent band NSF RAS RAS passive 21.5-24.0 User UL Not Required Determined proposed isolation criteria for 23.6-24 GHz adjacent band 12

SBCS Peer to Peer Compatibility • Spectrum Utilization Is Maximized by Multiple Platform Re-use • Stratospheric platform geometry permits complete spectrum re-use on a coordinated basis • Analysis in downlink and uplink directions both show sufficient positive margin for overlapping systems following proposed Relying on spatial diversity, multiple airships can serve overlapping geographic areas in the same frequency bands regulations Interferer carrier to interferer ratio (dB) Victim carrier to interferer ratio (dB) Both at maximum PFD (including outside service area) and worst case geometry Both at maximum PFD (including outside service area) and worst case geometry Overlap is 40.7401% Interferer Area, 79.8276% Victim Area Overlap is 40.7401% Interferer Area, 79.8276% Victim Area • Example DL analysis with EG Stations separated by 40 km, Worst case geometry 60 Stations separated by 40 km, Worst case geometry 60 reference system and system -60 55 -60 55 from ITU working party 5C -40 50 -40 50 25 km platform • Carrier to interferer ratio of -20 separation 45 -20 45 NS (km) NS (km) both systems remains high 0 I V 40 0 I V 40 enough to permit 5.9 bps/Hz 20 40 km center 35 20 35 with centers separated at most 40 separation 30 40 30 40 km and airships separated at 25 25 most 25 km 60 20 60 20 -60 -40 -20 0 20 40 60 80 -60 -40 -20 0 20 40 60 80 EW (km) EW (km) SBCS service areas are not mutually exclusive 13

FS Point to Point over 21.5-23.6 GHz– Interference from EG System User Uplink Interference Geometry & Analysis Results • SBCS-UT antennas have high rolloff and elevation angle – present low EIRP to terrestrial receivers • Analysis determines protection contour for each licensed receiver • UT in contour cannot reuse RX licensed channels Interference • Allows pre-coordination for rapid deployment Geometry • Protection contours are small enough that SBCS network controller can assign bands to UTs based on constraints that honor coordinations Terrestrial FS System Protection Contour SBCS-UT Deployment Planning Map Example FS RX 1 uses 50 MHz Reuse of that 50 MHz by SBCS-UT FS RX 1 within contour would result in FS RX 3 negative margin against FS RX 2 protection criteria Terrain and FCC license Notional Protection Contours database data used to evaluate realistic protection contours FS fully protected by coordinating constraints on UT location and/or spectrum 14

Petition for Rulemaking • Scope: Limited to SBCS User Links (21.5-24.0, 25.25-27.5 GHz) and Feeder Links (70/80 GHz) • Seek new primary FIXED allocations or footnotes in the 23.6-24.00 and 25.25-27.5 GHz bands • New allocations could be limited to stratospheric-based communications service (SBCS) operations, if appropriate • Service and operational rules for non-exclusive systems operating as a FIXED service in both urban and rural areas • Foundation for SBCS would be compatibility with incumbent operators in shared spectrum • Proposed technical rules will ensure compatibility with incumbents in many scenarios (e.g., ISS, EESS, some AMS) • Proposed rules would provide for coordination with other Fixed Services in 21.5-23.6 GHz range and in E-Band in fashion consistent with current framework with slight modifications • Proposed rules would provide for service-area specific coordination with incumbents where necessary (AMS, EESS, SRS, RAS) SBCS offers new technologies and services meriting Section 7 treatment of the Petition and the ensuing rulemaking 15

Petition for Rulemaking (cont’d) • SBCS licensing rules should provide for non-exclusive SBCS assignments • Through coordination, multiple SBCS systems can serve the same geography in the same bands • No mutual exclusivity • In UL bands, would also share with “traditional” Fixed Services • SBCS licenses should be granted on a rolling-wide area basis (REAs) • STRAPS and User Terminal links (uplinks) should be registered prior to deployment • Appropriate rural commitments should be considered • Bringing-into-use obligations, discontinuance rules, and transfer restrictions • Licensees can choose to operate as a private carrier or a common carrier 16

Next Steps • Continue briefings with Federal and non-Federal stakeholders • File Petition for Rulemaking • EG and Lockheed Martin plan to implement experimental licensing plan providing demonstrations of capabilities and compatibility and leading to deployment of airship prototype in next few years 17


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