Attachment Space Exploration Ho

Space Exploration Ho

DECISION submitted by IB, FCC

Grant

2019-07-25

This document pretains to SAT-STA-20190717-00063 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019071700063_1817826

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S2983         SAT-STA-20190717-00063      1B20 19002726                                            ~                          ~        ~ q~J ~
Space Exploration Holdings, LLC                                                              ,llSIgn S’3Oi~~’ GrantDate C~7 ~25~ i.              ‘~
SpaceX
                                                                                             (or’other identifier)
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                                                                                                 ••.~    ~,    :‘~Terfl10~t~          3od~~                  3060—0678
                                                                 GRANTED             ~       From_______            ,        T~
        Date & Time Filed: Jul 17 2019 4:28:48:486PM          I ntcrn HI ~nHl Bureau     •
                                                                                             Approvcd:        ~     ~,.
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        File Number: SAT STA 20190717—00063                ‘~w;th z~’4hoi5
        Callsign:                                                                                               C

                                                   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:
        Space Station STA Extension 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-STA-20190717-00063

 IBFS File No(s):         SAT-STA-20190717-00063                                                    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 (1T&C); Testing               International Bureau
                                                                                            Satellite_Division
 Scope of Grant:          Special temporary authority (STA) for an additional period of 30 days for Launch and
                          Early Orbit-Phase (LEOP) operations necessary to (1) perform Tf&C necessary for orbit-
                          raising; arid (2) communicate with seven Ku-band earth stations to test the communications
                          payload on each of.60 satellites that were deployed on May 23, 2019.’
 Service Area(s):         Not Applicable

 Frequencies:             TT&C Frequencies
                          12.22 1 0Hz (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 0Hz (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 Tf&C frequencies and test frequencies
 specified above.
          5.       Operations authorized here must comport with the conditions imposed in DA 19~342.2
 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.

  SpaceX notified that it would accept grant of special temporary authority for 30 days, rather than 60 days. Letter from
Henry Gola, Counsel for DG Consents Sub, Inc., to Stephen Duall, Chief, Satellite Policy Branch, filed July 3, 2019.
2 Space Exploration Holdings, LLC, Order and Authorization, DA 19-342 (lB rel. Apr. 26, 2019) (SpaceX Modification

Order).

                                                        Page 1 of 2


                                      ATTACHMENT TO GRANT
                                      Space Exploration Holdings, LLC
                                  IBFS File No. SAT-STA-20190717-00063


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         July 25, 2019
Date:
Term Dates     From: July 24, 2019                To: period of 30 days




                          Duall
               Chief, Satellite Policy Branch




                                                  Page 2 of 2


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 SATSTA2O 19040500023 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
~ 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 extension of special temporary authority for the first tranche of its NGSO
     satellites to communicate with Ku-band gateway and TT&C earth stations for an additional
     60 days.




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                                                  II. Title of Person Signing
Patricia Cooper                                                             Vice President, Satellite Government Affairs
12. Please supply any need attachments.
 Attachment I: STA Extension Reques                 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 3 12(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                  REQUEST FOR EXTENSION OF SPECIAL TEMPORARY AUTHORITY

         On May 9, 2019, the Commission granted Space Exploration Holdings, LLC (“SpaceX”)
Special Temporary Authority (“STA”) for the first tranche of its non-geostationary orbit
(“NGSO”) satellites launched on May 24, 2019 to communicate with seven earth stations operated
by its sister company, SpaceX Services, Inc. (“SpaceX Services”). SpaceX respectfully requests
that the Commission extend that STA for an additional 60 days for the reasons discussed below.

         SpaceX has been authorized to launch and operate a constellation of 4,425 NGSO satellites
(call sign S2983/S3018) using Ku- and Ka-band spectrum. Pursuant to the STA, SpaceX has been
communicating with an earth station to conduct telemetry, tracking, and control (“TT&C”)
functions during orbit raising,2 and has also been communicating with six Ku-band gateway earth
stations to test the communications payload on each of its satellites.3 SpaceX has operated with
these earth station pursuant to the STA for nearly two months, and has received no complaints
from any other authorized spectrum user.

         Allowing continued communications between the SpaceX space stations and SpaceX
Services earth stations while applications for the latter are being processed would serve the public
interest. The STA covers TT&C functions that are essential to commanding the spacecraft and
ensuring the health and safety of SpaceX’s nascent constellation. The STA also allows SpaceX to
confirm the operational status of its satellites. While much of the orbit-raising phase is now
complete, there are still some satellites that have yet to reach their authorized altitude. In addition,
there are two spacecraft that are being intentionally de-orbited in order to assess performance
during this phase of the mission. Extending the STA would allow SpaceX to continue to provide
TT&C functions that are essential to commanding all of these spacecraft and ensuring continuing
monitoring of and control over SpaceX’s nascent constellation, as well as maintaining
communications with these craft to assess their functionality. Accordingly, extension of the STA
will continue serve the public interest by enhancing space safety and promoting the health and
safety of SpaceX’s NGSO constellation.

        SpaceX will continue to operate on a non-interference basis, and in conformance with 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, against harmful


    See Public Notice, Rep. No. SAT-01388 (rel. May 10, 2019). As required under the STA, SpaceX confirmed
    the launch and commencement of operations date for its satellites, which began the term of the STA.
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). SpaceX Services received complementary STA requests for these earth
    stations to communicate with the SpaceX NGSO satellites.


interference. In the extremely unlikely event that harmful interference should occur due to
transmissions to or from its earth station, 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.

        Accordingly, SpaceX requests that the Commission extend the STA for these space stations
for up to an additional 60 days.


                       HARRIS, WILTSHIRE                                 I919MSTREETNW
                       & GRA  kikilS
                           IkININI     LLP                               SUITE800
                                                                         WASHINGTON DC 20036

                                                                         TEL +1 2027301300
                                                                         FAX+1 2027301301
July 25, 2019                                                            HWGLAW.COM

                                                                         AHORNEYS AT LAW

VIA ELECTRONIC FILiNG
Marlene 1-1. Dortch
Secretary
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, DC

       Re:      Space Exploration Holdings, LLC, IBFS File 7\T0• SAT-STA-2019071 7-00063

Dear Ms. Dortch:

        On July 17, 2019, Space Exploration Holdings, LLC (“SpaceX”) filed the above
referenced request that the Commission extend for an additional 60 days the special temporary
authority (“STA”) under which it is currently communicating with seven earth stations. This is
to confirm that Space X has no objection to a grant of a 30-day STA in the alternative.

                                             Sincerely,




                                             William M. Wiltshire
                                             Counsel to SpaceX


       Stephen Duall



Document Created: 2019-07-26 12:16:03
Document Modified: 2019-07-26 12:16:03

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