Attachment TT&C STA Request

This document pretains to SES-STA-INTR2019-01012 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201901012_1645572

                          REQUEST FOR SPECIAL TEMPORARY AUTHORITY
       SpaceX Services, Inc. (“SpaceX Services”), pursuant to Section 25.120 of the
Commission’s rules, hereby requests Special Temporary Authority (“STA”) to operate a telemetry,
tracking, and control (“TT&C”) earth station for up to 60 days to communicate with the first
tranche of non-geostationary orbit (“NGSO”) satellites to be launched by its sister company, Space
Exploration Holdings, LLC (“SpaceX”). SpaceX Services currently has an application pending
for a TT&C earth station located in Brewster, WA. 1 It would operate the earth station under the
requested STA with the technical characteristics set forth in that pending application, with
transmissions occurring in the following frequencies: 12.221 GHz (downlink) and 13.925 GHz
(uplink).
         The Commission has good cause to approve this request to enhance the safety of space.
Specifically, the requested STA would cover TT&C functions from the moment the SpaceX
satellites are inserted into orbit and as they are raised to their authorized operational altitude. These
functions are essential to commanding the spacecraft and ensuring continuing monitoring of and
control over SpaceX’s nascent constellation. Accordingly, the STA will serve the public interest
by enhancing space safety and promoting the health of SpaceX’s NGSO constellation.
        SpaceX Services will operate on a non-interference basis. As set forth in the underlying
earth station applications, these gateways will protect terrestrial and space systems in shared
spectrum bands. Specifically, they 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, against harmful interference. In addition, SpaceX Services
has completed frequency coordination for its proposed earth station site and demonstrated that its
operations will not affect U.S. Navy or NASA systems in the band, providing additional assurance
that it can operate on a non-interference basis. In the extremely unlikely event that harmful
interference should occur due to transmissions to or from its earth station, SpaceX Services will
take all reasonable steps to eliminate the interference. Should an issue arise, SpaceX Services 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.




1
    See IBFS File No. SES-LIC-INTR2019-00966. That application contains all relevant operational characteristics
    and is hereby incorporated herein to the extent necessary.



Document Created: 2019-04-05 22:52:42
Document Modified: 2019-04-05 22:52:42

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