Attachment Narrative App

This document pretains to SES-LIC-INTR2019-00966 for License on a Satellite Earth Station filing.

IBFS_SESLICINTR201900966_1643354

                           APPLICATION FOR TT&C EARTH STATION

    I.       OVERVIEW
         The Commission has authorized Space Exploration Holdings, LLC (“SpaceX”) to launch

and operate a constellation of 4,425 non-geostationary orbit (“NGSO”) satellites (call sign

S2983/S3018) using Ku- and Ka-band spectrum. 1 In doing so, the Commission recognized that

granting the SpaceX Authorization would “enable SpaceX to bring high-speed, reliable, and

affordable broadband service to consumers in the United States and around the world, including

areas underserved or currently unserved by existing networks.” 2                       SpaceX intends to begin

launching satellites to populate its constellation later this year.

         This application, filed by a sister company, SpaceX Services, Inc. (“SpaceX Services”),

seeks authority to operate an earth station that SpaceX will use to perform telemetry, tracking, and

control (“TT&C”) functions for its NGSO system. Consistent with SpaceX’s space station

authorization, this earth station will transmit in the 13.9-13.95 GHz band and receive in the 12.2-

12.25 GHz band.

         Below, we discuss certain spectrum sharing issues relevant to the operation of these earth

stations. We then demonstrate that grant of this application would serve the public interest. Lastly,

we provide technical information to supplement the information provided on Form 312. To

support its ambitious timetable for launching satellites and deploying broadband services, SpaceX

Services requests that the Commission grant the requested license as expeditiously as possible.




1
    See Space Exploration Holdings, LLC, 33 FCC Rcd. 148 (2018) (“SpaceX Authorization”). 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-20181108-00083 (Nov.
    8, 2018).
2
    SpaceX Authorization, ¶ 1.

                                                          1


    II.      SPECTRUM SHARING ISSUES

          The Commission has allocated the Ku-band uplink band (13.9-13.95 GHz) that SpaceX

Services proposes to use for this TT&C earth station on a primary basis only to FSS. However,

the downlink band (12.2-12.25 GHz) is shared with other commercial and government services.

SpaceX has engineered its NGSO system design to achieve a high degree of flexibility to facilitate

spectrum sharing with other authorized satellite and terrestrial systems. SpaceX is aware of its

obligations under its Authorization to protect terrestrial and space systems in these shared bands,

particularly 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. 3 The

Commission has found that compliance with these EPFD and PFD limits is sufficient to protect

GSO systems and terrestrial systems, respectively, against harmful interference. 4 In addition,

SpaceX Services recognizes that its earth station operations will be subject to certain sharing

conditions, including those relating to the Multichannel Video and Data Distribution Service. 5

SpaceX is confident that the highly advanced and flexible capabilities of its NGSO system,

including the earth station proposed by SpaceX Services herein, will be able to comply with these




3
    See SpaceX Authorization, ¶¶ 40(b), (d), and (e); 47 C.F.R. § 25.115(f)(1) (incorporating certification requirement
    in 47 C.F.R. § 25.146(a)(2)).
4
    See, e.g., Amendment of Parts 2 and 25 of the Commission's Rules to Permit Operation of NGSO FSS Systems
    Co-Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, 16 FCC Rcd. 4096, ¶ 77
    (2000) (concluding that implementation of EPFD limits “will adequately protect GSO FSS networks”); 47 C.F.R.
    § 25.289 (NGSO satellite systems that comply with EPFD limits will be deemed not to cause unacceptable
    interference to any GSO network); Amendment of Parts 2 and 25 of the Commission's Rules to Permit Operation
    of NGSO FSS Systems Co-Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, 16
    FCC Rcd. 4096, ¶ 42 (2000) (observing PFD limits should protect terrestrial systems in the band).
5
    See, e.g., 47 C.F.R. §§ 25.115(f)(2); 25.208(o); and 101.1409.

                                                          2


limitations.

           In addition, the attached Technical Annex includes a demonstration that the proposed

TT&C earth station will comply with the criteria established by the Commission for the protection

of U.S. Navy shipboard radiolocation operations (RADAR) and NASA space research activities

in the 13.75 - 14.0 GHz band against harmful interference. 6


    III.      GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST

           Granting this application would serve the public interest by helping to speed broadband

deployment throughout the United States by authorizing the ground-based component of SpaceX’s

satellite system. U.S. and worldwide demand for broadband services and Internet connectivity

continues to increase with escalating requirements for speed, capacity, and reliability and ongoing

adaptations for usage. The volume of traffic flowing over the world’s networks has exploded, with

one report estimating that annual global Internet protocol traffic reached 1.5 zettabytes in 2017 –

meaning that approximately 1,500 billion gigabytes of data were exchanged worldwide last year. 7

           Yet, as the Commission has recognized, many communities across the United States and

the world still lack access to reliable broadband connectivity, preventing them from fully

participating in economic, social, and civic activities. 8 To help close this digital divide, SpaceX is


6
    See Amendment of Parts 2, 25, and 90 of the Commission’s Rules to Allocate the 13.75-14.0 GHz Band to the
    Fixed-Satellite Service, 11 FCC Rcd. 11951, ¶¶ 18-22 (1996).
7
    See Cisco Visual Networking Index: Forecast and Methodology, 2017-2022, at 1 (Nov. 26, 2018), available at
    https://www.cisco.com/c/en/us/solutions/collateral/service-provider/visual-networking-index-vni/white-paper-
    c11-741490 html.
8
    See, e.g., Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in
    a Reasonable and Timely Fashion, 33 FCC Rcd. 1660, ¶ 50 (2018) (noting that “over 24 million Americans still
    lack fixed terrestrial broadband at speeds of 25 Mbps/3 Mbps,” and that “the gap in rural and Tribal America
    remains notable: 30.7 percent of Americans in rural areas and 35.4 percent of Americans in Tribal lands lack
    access to fixed terrestrial 25 Mbps/3 Mbps broadband”). Internationally, the disparities between broadband access
    and absence are even greater, with 4.2 billion people (or 57% of the world’s population) offline. See BROADBAND
    COMMISSION FOR SUSTAINABLE DEVELOPMENT, “Open Statement from the Broadband Commission for
    Sustainable Development to the UN High-Level Political Forum (HLPF)” (July 11, 2016), available at
    http://broadbandcommission.org/Documents/publications/HLPF-July2016.pdf.             See     also     BROADBAND

                                                         3


designing, constructing, and deploying an innovative, cost-effective and spectrum-efficient

satellite system capable of delivering robust broadband service to customers around the world.

SpaceX has already secured U.S. authority for the space station components of its NGSO system.

This application takes the next step by seeking authority for a TT&C earth station that will be used

in coordination with others located around the world to ensure that SpaceX has sufficient command

and control over its satellite system. Accordingly, an expeditious grant of this application would

serve the public interest.

                                                      Respectfully submitted,

                                                      SPACEX SERVICES, INC.


                                                      By: _/s/ Patricia Cooper________
                                                          Patricia Cooper
 William M. Wiltshire                                     Vice President of Satellite Government
 Paul Caritj                                               Affairs
 HARRIS, WILTSHIRE & GRANNIS LLP                          David Goldman
 1919 M Street, N.W.                                      Director, Satellite Policy
 Suite 800
 Washington, DC 20036                                 SPACE EXPLORATION TECHNOLOGIES CORP.
 202-730-1300 tel                                     1155 F Street, NW
 202-730-1301 fax                                     Suite 475
                                                      Washington, DC 20004
 Counsel to SpaceX                                    202-649-2700 tel
                                                      202-649-2701 fax




   COMMISSION FOR SUSTAINABLE DEVELOPMENT, “The State of Broadband 2015,” at 8 (Sep. 2015), available at
   http://www.broadbandcommission.org/Documents/reports/bb-annualreport2015.pdf (“A large body of evidence
   has now been amassed that affordable and effective broadband connectivity is a vital enabler of economic growth,
   social inclusion and environmental protection.” (footnotes omitted)).

                                                        4


                                            TECHNICAL ANNEX

        In this Technical Annex, SpaceX Services provides additional information on the proposed

operations of its gateway earth station to supplement the data provided in Schedule B to Form 312

filed with this narrative application. 1

A. Antenna Patterns

        Section 25.209 of the Commission’s rules imposes reference antenna pattern requirements

for certain satellite earth stations. Most of these relate to earth stations communicating with GSO

systems, as the rule was developed to facilitate GSO-to-GSO sharing where a constant level of

interference is present. 2       However, Section 25.209(h) specifies performance standards for

transmitting antennas in a gateway earth station communicating with NGSO FSS satellites in the

10.7-11.7 GHz and 14.4-14.5 GHz bands. 3 For this purpose, the Commission defines “NGSO FSS

gateway earth station” as an earth station or complex of multiple earth station antennas that

supports the routing and switching functions of an NGSO FSS system and that does not originate

or terminate communications traffic. 4 The TT&C earth station proposed in this application is not

such a “gateway.”

        Accordingly, the Commission’s earth station licensing rules that are predicated on antenna

performance standards do not apply to this application. For example, Section 25.132 of the

Commission’s rules provides that applications for transmitting FSS earth stations must include a



1
    To the extent relevant, SpaceX Services hereby incorporates the technical information submitted with SpaceX’s
    space station applications. See IBFS File Nos. SAT-LOA-20161115-00118, SAT-LOA-20170726-00110, and
    SAT-MOD-20181108-00083.
2
    See Amendment of Parts 2 and 25 of the Commission's Rules to Permit Operation of NGSO FSS Systems Co-
    Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, 16 FCC Rcd. 4096, ¶ 81 (2000)
    (“Ku-Band NGSO Order”). But see 47 C.F.R. § 25.209(h) (specifying performance standards for transmitting
    gateway earth stations operating with Ku-band NGSO systems).
3
    See 47 C.F.R. § 25.209(h).
4
    Id. § 25.103.

                                                      A-1


certification that the applicant has reviewed the results of a series of radiation pattern tests

performed on representative equipment in representative configurations, and the test results

demonstrate that the equipment meets relevant off—axis gain standards in Section 25.209. Since

no such standards apply to the TT&C earth station proposed in this application, no such

certification is required.

         In support of its application, SpaceX Services (1) states that the half power beamwidth for

its proposed TT&C earth station is 0.26 degrees at 13.9 GHz, and (2) provides below information

on the EIRP mask for its proposed five—meter TT&C antenna."

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5_   In addition, consistent with the requirements of footnote US356 to the Table of Frequency Allocations, the
     antenna for this earth station has a diameter greater than 4.5 meters and the EIRP of its emissions falls between
     68 dBW and 85 dBW. See 47 C.F.R. §2.106. n. US356.

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                                A—4


B. Compliance with Frequency Coordination Requirements for the 13.75 - 14.0 GHz Band

    1. Background

         The following analysis demonstrates that the TT&C satellite earth station in Brewster, WA
proposed by SpaceX Services will comply with the requirements set forth in Extended Ku-Band
Coordination Order.6 Specifically, this analysis addresses the potential interference from the earth
station to U.S. Navy shipboard radiolocation operations (RADAR) and the NASA space research
activities in the 13.75 - 14.0 GHz band. The parameters for the earth station are:

    •   Coordinates (NAD83):                              48.148621° N, 119.701131° W

    •   Satellite Location for Earth Station:             SpaceX NGSO constellation

    •   Frequency Band:                                   13.75-14.0 GHz for uplink

    •   Polarizations:                                    Circular

    •   Emissions:                                        2M7D7W, 13M5D7W, 41M4D7W

    •   Modulation:                                       Digital

    •   Maximum Aggregate                                 Uplink EIRP: 70.9 dBW for all carriers

    •   Transmit Antenna Characteristics
           o Antenna Size:                                5.0 meter diameter
           o Antenna Type/Model:                          CGC Type 4
           o Gain:                                        55 dBi

    •   RF power into Antenna Flange:
                                                          2.7 MHz modulation:
                                                          15.9 dBW or -12.4 dBW/4 kHz (Maximum)

                                                          13.5 MHz modulation:
                                                          15.9 dBW or -19.4 dBW/4 kHz (Maximum)

                                                          41.4 MHz modulation:
                                                          15.9 dBW or -24.2 dBW/4 kHz (Maximum)

    •   Minimum Elevation Angle:                          5°

    •   Side Lobe Antenna Gain:                           29 - 25*log(θ), from ITU S.1428 pattern
                                                          11.5 dBi at 5° separation

6
    See Amendment of Parts 2, 25, and 90 of the Commission’s Rules to Allocate the 13.75-14.0 GHz Band to the
    Fixed-Satellite Service, 11 FCC Rcd. 11951, ¶¶ 18-22 (1996) (“Extended Ku-Band Coordination Order”).

                                                    A-5


Because the above uplink spectrum is shared with the Federal Government, coordination in this
band requires resolution data pertaining to potential interference between the earth station and both
Navy Department and NASA systems. Potential interference from the earth station could affect
the Navy and/or NASA systems in two areas: (1) radiolocation and radio navigation, (2) data relay
satellites.

2. Potential Impact to Government Radiolocation (Shipboard RADAR)

       Radiolocation operations (RADAR) may occur anywhere in the 13.4 – 14.0 GHz frequency
band aboard ocean-going United States Navy ships. The Commission has allocated the top 250
MHz of this 600 MHz band to the Fixed Satellite Service (FSS) on a co-primary basis with the
radiolocation operations and provides for an interference protection level of -167 dBW/m2/4 kHz.7

         The closest distance to the shoreline from the Brewster earth station is approximately 185.2
km West toward Marysville, WA. In addition, the Cascade mountain range lies in between the
earth station and the shore, with a height of 10,500 ft. The calculation of the power spectral density
at this distance is given by:
                                            2M7D7W             13M5D7W               41M4D7W

     1. Clear Sky EIRP (dBW)                   70.9                70.9                 70.9

     2. Carrier Bandwidth                   2.7 MHz             13.5 MHz             41.4 MHz

     3. PD at antenna input, after            -12.4                -19.4               -24.2
        losses (dBW/4 kHz)
     4. Transmit Antenna Gain                                     55 dBi

     5. Antenna Gain Horizon                             11.5 dBi at 5° separation

                                                           (ITU S.1428 pattern)

     6. Antenna Elevation Angle                                     5°


The proposed earth station will radiate interference toward Puget Sound according to its off-axis
side-lobe performance. A conservative analysis, using the ITU S.1428 reference pattern, results
in off-axis antenna gain of 11.5 dBi toward the Puget Sound. The signal density at the shoreline,
through free space, is:

2.7 MHz Carrier
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBW/m2).



7
    See id. ¶ 20.

                                                A-6


        = -12.4 dBW/4 kHz + 11.5 dBi – 10*log[4*PI*(185200)2]
        = -117.2 dBW/m2/4 kHz + Additional Path Losses (~98.3 dB)
        = -215.5 dBW/m2/4 kHz

13.5 MHz Carrier
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBW/m2).

        = -19.4 dBW/4 kHz + 11.5 dBi – 10*log[4*PI*(185200)2]
        = -124.2 dBW/m2/4 kHz + Additional Path Losses (~98.3 dB)
        = -222.5 dBW/m2/4 kHz

41.4 MHz Carrier
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBW/m2).

        = -24.2 dBW/4 kHz + 11.5 dBi – 10*log[4*PI*(185200)2]
        = -129.0 dBW/m2/4 kHz + Additional Path Losses (~98.3 dB)
        = -227.3 dBW/m2/4 kHz

Our calculations identified additional path losses of approximately 98.3 dB including absorption
loss and earth diffraction loss for the actual path profiles from the earth station to the nearest
shoreline. This includes the Cascade mountain range, which lies in between Brewster and Puget
Sound, with a peak height of 10,500 ft.
        The worst-case calculated PFD including additional path losses to the closest shoreline
location is -215.5 dBW/m2/4 kHz for 2.7 MHz carrier, -222.5 dBW/m2/4 kHz for 13.5 MHz carrier,
and -227.3 dBW/m2/4 kHz for 41.4 MHz carrier. All carriers are a minimum of 48.5 dB below
the -67 dBW/m2/4 kHz interference criteria established in the Extended Ku-Band Coordination
Order. Therefore, there should be no interference to the US Navy RADAR from the Brewster
earth station due to the distance and the terrain blockage between the site and the shore.


3. Potential Impact to NASA’s Tracking and Data Relay Satellite System (TDRSS)

        The geographic location of the SpaceX Services earth station in Brewster, WA is outside
the 390 km radius coordination contour surrounding NASA’s White Sands, New Mexico ground
station complex. Therefore, the TDRSS space-to-earth link will not be impacted by the proposed
earth station in Brewster, WA. 8

        The TDRSS space-to-space link in the 13.772 – 13.778 GHz band is assumed to be
protected if an earth station produces an EIRP less than 71 dBW/6 MHz in this band. 9 The five-
meter earth station antenna will have an EIRP less than 71 dBW/6 MHz for all carriers in this

8
    See id. ¶ 21.
9
    See id. ¶ 34.

                                               A-7


band. The total EIRP is 70.9 dBW for all carriers. For the 2.7 MHz carrier, the equivalent EIRP
per 6 MHz segment will remain at 70.9 dBW/6 MHz. For the 13.5 MHz carrier the equivalent
EIRP is 67.4 dBW/6 MHz. For the 41.4 MHz carrier the equivalent EIRP is 62.5 dBW/6 MHz.

        All cases remain below the EIRP threshold of 71 dBW/6 MHz. Therefore, there should be
no interference to the TDRSS space-to-space link from any carriers.


4. Coordination Issue Result Summary and Conclusions
       The results of the analysis and calculations performed in this exhibit indicate that
compatible operation between the TT&C earth station at the Brewster facility and the U.S. Navy
and NASA systems space-to-earth link are possible for all proposed carriers. Operations in NASA
systems space-to-space link (13.772 – 13.778 GHz) will also be permitted for all carriers.




                                             A-8



Document Created: 2019-04-27 00:15:24
Document Modified: 2019-04-27 00:15:24

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