Attachment Space Exploration Ho

Space Exploration Ho

DECISION submitted by IB,FCC

Grant with conditions

2019-05-09

This document pretains to SAT-STA-20190405-00023 for Special Temporal Authority on a Satellite Space Stations filing.


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S298313018   SAT~STA-2O190405~~23
Space Exploration Holdings LLC
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SpaceX
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                                                                        GRANTED~
         Date & Time Filed: Apr 5 2019 4:56:44:580PM                  I n~erna1 onal l3ureau    Approved                i~~w
         File Number: SAT STA 20190405 00023                          ~wth      Ccr~on~’                                 ~
         Cailsign:
                                                     FEDERAL COMMUNICATIONS COMMISSION
                                          APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                                 FOR OFFICIAL USE ONLY

          APPLICANT INFORMATION
        Enter a description of this application to identify it on the main menu:
        First LEOP STA Request
         1. Applicant

                     Name:          Space Exploration Holdings, LLC    Phone Number:                                202 649 2700

                     DBA Name:                                         Fax Number:                                  202 649 2701
                     Street:        1155 F Street, N.W.                E—Mail:                                      patricia.cooper@spacex.cOm
                                    Suite 475
                     City:          Washington                         State:                                           DC
                     Country:       USA                                Zipcode:                                     20004
                     Attention:     Ms Patricia Cooper


                                             ATTACHMENT TO GRANT
                                              Space Exploration Holdings, LLC
                                          IBFS File No. SAT-S TA-20 190405-00023

    IBFS File No(s):         SAT-STA-20190405-00023                                             GRANTED           —


    Licensee/Grantee:        Space Exploration Holdings, LLC                                    With Conditions
    Call Sign:               S2983/S3018
    Satellite Name:          SpaceX Ku/Ka-band Constellation
    Orbital Location:        Non-geostationary orbit (NGSO)
    (required station-
    keeping tolerance)
    Administration:          United States of America
    Nature of Service:       Telemetry, Tracking, and Command (TT&C); Testing               International Bureau
                                                                         V                    Satellite Division
    Scope of Grant:          Special temporary authority (STA) for a period of 60 days for Launch and Early Orbit-
                             Phase (LEOP) operations necessary to (1) perform TT&C necessary for orbit-raising; and
                             (2) communicate with seven Ku-band earth stations to test the communications payload on
                             each of the up to 75 satellites to be imminently launched.’
    Service Area(s):         Not Applicable

    Frequencies:             TT&C Frequencies
                             12.22 1 GHz (space-to-Earth) and 13.925 GHz (Earth-to-space)

                             Payload Testing Frequencies
                             10.7-12.7 GHz (space-to-Earth)
                             14.0-14.5 GHz (Earth-to-space).

    Operations under this grant must comport with the legal and technical specifications set forth by the
    applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This
    grant is also subject to the following conditions:

             1.      All operations under this grant of special temporary authority must be on an unprotected and non-
    harmful interference basis, i.e., SpaceX must not cause harmful interference to, and must not claim protection from
    interference caused to it by, any other lawfully operating station.
             2.    In the event of any harmful interference under this grant of special temporary authority, SpaceX
    must cease operations immediately upon notification of such interference and must inform the Commission, in
    writing, immediately of such an event.
            3.      SpaceX’s payload-frequency operations must be limited to testing and must not include the
    provision of commercial services.
            4.       During LEOP operations SpaceX must operate only the T~&C frequencies and test frequencies
    specified above.
             5.       Operations authorized here must comport with the conditions imposed in DA l9~342.2
            6.      The term of this authorization commences on the date of launch of the up to 75 satellites covered
    by this grant. SpaceX must notify the Chief of the Satellite Division, in writing, of the date of launch and the
    commencement of this grant of special temporary authority.




    See Basis for Grant, set forth on pages 3-4 of this Attachment.
2   Space Exploration Holdings, LLC, Order and Authorization, DA 19-342 (lB rel. Apr. 26, 2019) (SpaceX Mod~fication
Order).

                                                           Page 1 of 4


                                      ATTACHMENT TO GRANT
                                       Space Exploration Holdings, LLC
                                   IBFS File No. SAT-STA-20190405-00023

Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.

This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 CFR § 0.261,
and is effective upon release.

Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
amended, 47 U.S.C. § 309(h).

Action         May 9, 2019
Date:
Term Dates     From: see conditions               To: period of 60 days

Approved:



               Stephen Duall
               Chief, Satellite Policy Branch




                                                  Page 2 of 4


                                          ATTACHMENT TO GRANT
                                          Space Exploration Holdings, LLC
                                      IBFS File No. SAT-STA-20190405-00023

                                                    Basis for Grant


        On April 18, 2019, World Vu Satellites Limited (OneWeb) submitted a letter opposing SpaceX’s request
for special temporary authority (STA).1 On April 23, 2019, SpaceX responded to OneWeb’s letter.2 On April 25,
2019, EchoStar Satellite Operating Corporation and Hughes Network Systems, LLC (together with their affiliates,
“EchoStar”), and Intelsat License LLC (Intelsat) submitted a written exparte presentation in response to
developments in the above-referenced proceedings concerning, inter a/ia, the SpaceX modification application
and the space station STA request.3
       OneWeb raises concerns that SpaceX fails to present “extraordinary circumstances” necessitating
temporary operations, as required by Section 309(f) of the Communications Act and Section 25.120(b) of the
Commission’s rules.4 In this instance, SpaceX seeks authority for special operations (launch and early operations
and testing) of a temporary nature (for brief period of time prior to commencement of commercial operations).
Such operations have been granted through STAs routinely in the past for similar in-orbit testing (TOT) operations
for geostationary satellites prior to commencing operations,5 and for LEOP operations for NGSO satellites.6 The
ability to communicate with satellites during the orbit-raising phases, as requested in this application, is important
to ensure proper functioning and to identify and correct any issues before satellites reach operational orbit.
Accordingly, grant of the requested STA for SpaceX’ s non-geostationary satellites serves the public interest.
         OneWeb also argues that SpaceX is attempting to shortcut the Commission’s review of SpaceX’s
modification application that was pending before the Commission at the time SpaceX filed its space station
special temporary authority.7 OneWeb further asserts that the requests for STA were incomplete as filed.8 As an
initial matter, SpaceX’s modification application was granted on April 26, 2019,~ and thus the argument regarding
shortcutting the review of then-pending modification application is moot. In addition, we find that SpaceX’ s




  Letter from Brian D. Weimer, Counsel to OneWeb, to Marlene H. Dortch, Secretary, FCC, dated April 18, 2019 (OneWeb
Opposition).
2 See Letter from William M. Wiltshire, Counsel to SpaceX, to Marlene H. Dortch, Secretary, FCC, dated April 23, 2019.

  See Letter from Jennifer A. Manner, Senior Vice President, Regulatory Affairs, EchoStar Satellite Operating Company and
Hughes Network Systems, LLC; and Susan H. Crandall, Associate General Counsel, and Cynthia J. Grady, Senior Counsel,
Intelsat US LLC, to Marlene H. Dortch, Secretary, FCC, dated April 23, 2019.
“OneWeb Opposition at 1-2 (citing 47 U.S.C. § 309(f) and 47 CFR § 25.120(b)).
~ See, e.g., IBFS File Nos. SAT-STA-20l70302-00032, SAT-STA-20170314-00050, SAT-STA-20170526-00080,
SAT—STA—20 170718—00105, SAT-STA-20l 70921-00135, SAT-STA-201 80118-00007, SAT-STA-2017 1218-00173, SAT
STA-20180214-00016, & SAT-STA-20l80905-00066. Certain temporary operations (except in-orbit testing) are already
permitted by rule, without the need to seek further Commission authorization, for satellites authorized to operate in the
geostationary orbit. 47 CFR § 25.282 (“A space station authorized to operate in the geostationary satellite orbit under the
part is also authorized in connection with short-term, transitory maneuvers directly related to post-launch, orbit-raising
maneuvers, provided [certain conditions are met].”) There is no similar rule automatically authorizing the temporary
operations of satellites authorized to operate in non-geostationary orbits.
6 The Satellite Division has previously granted special temporary authority for launch and early operation phase (LEOP) for

NGSO space stations. See, e.g., IBFS File No. SAT-STA-20170726-00109 & SAT-STA-20180724-00055 (granting 180-day
STAs to Terra Bella for LEOPs).
~‘ OneWeb Opposition at 3-4.

81d at5.
~ Space Exploration Holdings, LLC, Order and Authorization, DA 19-342 (lB rel. Apr. 26, 2019) (SpaceX Modification
Order).
                                                      Page 3 of 4


                                             ATTACHMENT TO GRANT
                                            Space Exploration Holdings, LLC
                                        IBFS File No. SAT-STA-20190405-00023

request for STA provides, as required by our rule governing STA requests, “the full particulars of the proposed
operation including all facts sufficient to justify the temporary authority sought and the public interest therein.”
         12 The information provided in the STA request, in conjunction with the information in its modification

application that was incorporated by reference, is fully consistent with the information provided in other requests
for STA in connection with LEOP and in-orbit testing operations.
         Finally, EchoStar and Intelsat argue in their ex parte filing that the STA request made an insufficient
showing to grant a waiver of a condition on SpaceX’ s previous license grant that required, prior to the launch of
SpaceX’s system, the International Telecommunication Union to issue a “favorable” or “qualified favorable”
finding that SpaceX’s proposed operations will meet equivalent isotropically radiated power (EIRP) limits. This
issue was addressed by the International Bureau in the grant of SpaceX’ s modification application and is not a
basis for denial of grant of SpaceX’s request for STA.’3




1247    CFR § 25.120(a).
13   SpaceX Modification Order at para.28.
                                                    Page 4 of 4


2. Contact

             Name:         William M. Wiltshire                 Phone Number:                        202—730—1350
             Company:      Harris, Wiltshire & Grannis LLP      Fax Number:                          202—730—1301


             Street:       1919 M Street, NW                    E—Mail:                              wwiltshire@hwglaw.com
                           Suite 800
             City:         Washington                           State:                                DC
             Country:      USA                                  Zipcode:                             20036      —



             Attention:                                         Relationship:                        Legal Counsel


  (If your application is related to an application filed with the Commission, enter either the file number or the lB Submission ID of the related
application. Please enter only one.)
  3. Reference File Number SATMOD2OI8I 10800083 or Submission ID
  4a. Is a fee submitted with this application?
• If Yes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
0   Governmental Entity     ~ Noncommercial educational licensee
o Other(please explain):
4b. Fee Classification    CXW   —   Space Station (Non—Geostationary)
5. Type Request


o Change Station Location                              Extend Expiration Date                           Other


6. Temporary Orbit Location                                                7. Requested Extended Expiration Date
       NGSO


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     SpaceX requests special temporary authority for the first tranche of its NGSO satellites
     to communicate with Ku-band gateway and TT&C earth stations for 60 days after orbital
     injection.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     • Yes           No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR
1.2002(b) for the meaning of "party to the application" for these purposes.


10. Name of Person Signing                                                  11. Title of Person Signing
Patricia Cooper                                                             Vice President, Satellite Government Affairs
12. Please supply any need attachments.
 Attachment 1: LEOP STA Request                     Attachment 2:                                      Attachment 3:


          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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                            REQUEST FOR SPECIAL TEMPORARY AUTHORITY

        Space Exploration Holdings, LLC (“SpaceX”), pursuant to Section 25.120 of the
Commission’s rules, hereby requests Special Temporary Authority (“STA”) for the first tranche
of its non-geostationary orbit (“NGSO”) satellites to communicate with seven earth stations
operated by its sister company, SpaceX Services, Inc. (“SpaceX Services”). SpaceX has been
authorized to launch and operate a constellation of 4,425 (“NGSO”) satellites (call sign
S2983/S30 18) using Ku- and Ka-band spectrum.’ It intends to launch its first tranche of satellites
in early May 2019, and seeks authority for operations during the orbit-raising phase.

        These operations fall into two categories. First, SpaceX would communicate with a TT&C
earth station to conduct telemetry, tracking, and control (“TT&C”) functions during orbit raising.2
These transmissions would occur in the following frequencies: 12.221 GHz (downlink) and
13.925 GHz (uplink). Second, SpaceX would communicate with six Ku-band gateway earth
stations to test the communications payload on each of its satellites.3 These operations would take
place throughout the 10.7-12.7 GHz (downlink) and 14.0-14.5 GHz (uplink) bands.

        The Commission has good cause to approve this request to enhance the safety of space.
Specifically, the requested STA would cover TT&C functions that are essential to commanding
the spacecraft and ensuring the health and safety of SpaceX’s nascent constellation. The STA
would also allow SpaceX to confirm the operational status of its satellites immediately upon
insertion, rather than waiting weeks while the satellites are obit raising to ensure proper
functioning. This testing would yield a number of public interest benefits. For instance, SpaceX
could act quickly in the unlikely event of a performance issue with one of its spacecraft to identify
and correct the problem even before the satellite reaches operational orbit. Accordingly, the STA
will serve the public interest by enhancing space safety and promoting the health and safety of
SpaceX’s NGSO constellation.

        SpaceX will operate on a non-interference basis. Consistent with its authorization, SpaceX
will observe the applicable equivalent power flux-density (“EPFD”) limits set forth in Article 22
and Resolution 76 of the ITU Radio Regulations and the applicable power flux-density (“PFD”)
limits set forth in the Commission’s rules and Article 21 of the ITU Radio Regulations, which the
Commission has found sufficient to protect GSO systems and terrestrial systems, respectively,


    See Space Exploration Holdings, LLC, 33 FCC Red. 148 (2018). SpaceX recently filed a modification application
    in which it proposes to relocate 1,584 satellites previously authorized to operate at an altitude of 1,150 km to an
    altitude of 550 km, and to make related changes to the operations of the satellites in this new lower shell of the
    constellation. See Application, IBFS File No. SAT-MOD-20181 108-00083 (Nov. 8, 2018). Those applications
    contain all relevant operational characteristics and are hereby incorporated herein to the extent necessary.
2   Although the Commission by rule authorizes TT&C operations for GSO satellites during the orbit-raising
    phase, it has not yet adopted a similar rule for NGSO systems (though one is currently under consideration).
    See 47 C.F.R. § 25.282; Mitigation of Orbital Debris in the New Space Age, FCC 18-159, ¶ 70 (rel. Nov. 19,
    2018).
    SpaceX Services currently has applications pending for six Ku-band gateway earth stations (located in North
    Bend, WA; Conrad, MT; Merrillan, WI; Greenville, PA; Redmond, WA; and Hawthorne, CA) and one TT&C
    earth station (located in Brewster, WA). See IBFS File Nos. SES-LIC-INTR2O19-00877 through -00882, -00966.
    SpaceX Services is filing complementary STA requests for these earth stations.


against harmful interference. In the extremely unlikely event that harmful interference should
occur due to transmissions to or from its spacecraft, SpaceX will take all reasonable steps to
eliminate the interference. Should an issue arise, SpaceX can be reached at satellite-operators
pager~spacex.com, which links to the pagers of appropriate technical personnel 24/7.

        The first tranche of SpaceX satellites is scheduled to be launched in early May 2019.
Accordingly, SpaceX Services requests that the Commission issue an STA structured to begin on
the launch date and remain in force for up to 60 days thereafter.



Document Created: 2019-05-09 15:23:17
Document Modified: 2019-05-09 15:23:17

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