Attachment Space Exploration Ho

Space Exploration Ho

DECISION submitted by IB, FCC

Grant with conditions

2019-09-04

This document pretains to SAT-STA-20190815-00075 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019081500075_1888407

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                                                                                      __________           To:        30 ‘&~jS       3060 0678
Date & Time Filed: Aug 15 2019 11:1 2:30:563A           International Bureau
File Number: SAT STA 20190815 00075                   ~w*h     coaihon~                             p~D4i
Calisign:                                                                                          c~i~tk~ ~ i3iarh
                                           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 Further STA Extension Request
1. Applicant

           Name:         Space Exploratior 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—20 190815—00075

 IBFS File No(s):        SAT—STA—20190815—00075
 Licensee/Grantee:       Space Exploration Holdings, LLC
 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

 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 TT&C necessary for orbit-
                         raising; and (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
                         12.221 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 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 TT’&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.




‘SpaceX notified that it would accept grant of special temporary authority for 30 days, rather than 60 days. Letter from
William M. Wiltshire, Counsel for SpaceX, to Stephen Duall, Chief, Satellite Policy Branch, filed July 25, 2019 (IBFS File
No. SAT-STA-20 190717-00063).
2 Space Exploration Holdings, LLC, Order and Authorization, DA 19-342 (lB rel. Apr. 26, 2019) (SpaceX Mod~fication

Order).

                                                       Page 1 of 2


                                      ATTACHMENT TO GRANT
                                     Space Exploration Holdings, LLC
                                 IBFS File No. SAT—STA—20190815—00075

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         September 4, 2019
Date:
Term Dates     From: August 25, 2019              To: period of 30 days

Approved:



               Stephen L,óuall
               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 SAT5TA2019071700063 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


 ~ Change Station Location                             Extend Expiration Date                           Other


6. Temporary Orbit Location                                                7. Requested Extended Expiration Date
       NGSO                                                                     20 19—09—23 00:00:00.0


8. Description   (If the complete descriptior 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
     30 days.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     o 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: 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”).’            The Commission
subsequently extended that STA through August 24, 201 9•2 SpaceX respectfully requests that the
Commission further extend that STA for an additional 30 days for the reasons discussed below.

         SpaceX has been authorized to launch and operate a constellation of 4,409 NGSO satellites
(call sign S2983/S301 8) 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 and initial on-station operations,3 and has also been communicating
with six Ku-band gateway earth stations to test the communications payload on each of its
satellites.4 SpaceX has operated with these earth station pursuant to the STA for nearly three
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 on an ongoing basis. 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


    See Public Notice, Rep. No. SAT-0 1388 (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   See Public Notice, Rep. No. SAT-0 1404 (rel. July 26, 2019).

    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 STAs for these earth stations
    to communicate with the SpaceX NGSO satellites.


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
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 30 days.



Document Created: 2019-09-05 15:27:27
Document Modified: 2019-09-05 15:27:27

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