Amazon urges FCC to reject SpaceX proposals for next-generation Starlink
Amazon urges FCC to reject SpaceX proposals for next-generation Starlink

          
          
SpaceX’s two proposals
SpaceX's FCC filing on August 18 proposed one configuration that "will more evenly spread capacity by latitude by targeting multiple inclinations, ensuring better, more consistent global coverage," along with a second configuration that "utilizes a smaller number of satellites per plane than Configuration 1, yet also spreads capacity more evenly by latitude for more consistent coverage across the globe." Another major difference between them is that "Configuration 1 fully leverages the upgraded satellite capabilities and the availability of Starship, bringing significantly increased capability to deliver satellites to orbit" while "Configuration 2 provides an alternative that also leverages the capabilities of the reliable Falcon 9 rocket," SpaceX said.
SpaceX said it prefers the first configuration but that neither of them requires "any additional spectrum or results in a significant increase in the potential for interference to any other spectrum user, including other NGSO [non-geostationary satellite orbit] licensees and current applicants."
Amazon says two proposals is one too many
Amazon wrote that the SpaceX approach forces the FCC and other parties to do twice as much technical work:
Forcing both the commission and interested parties to grapple with the interference concerns posed by two separate configurations doubles the technical effort of every operator faced with the task of reviewing the interference and orbital debris concerns raised by SpaceX's amendment. SpaceX points to this as a convenience, arguing that applying for both configurations will "enable the commission to evaluate both approaches even as development proceeds." It is SpaceX, however, that is required to evaluate and select among different approaches; both the commission and interested parties need only examine a single "comprehensive proposal."
Amazon contends that the SpaceX application violates a rule requiring applications to be complete and have no internal inconsistencies. The commission has said it applies the rule to avoid encouraging "speculative applications."
Amazon's filing continued:
Here, by leaving nearly every major detail unsettled—such as altitude, inclination, and even the total number of satellites—SpaceX's application fails every test that section 25.112(a)(1) enumerates. And with respect to the requirement that license applications contain a "comprehensive proposal," SpaceX's proposed amendment contains either two comprehensive proposals or none at all. The effects cascade throughout SpaceX's entire amendment. As one example, SpaceX is forced to seek a waiver of "the limitations in Schedule S" because, among other reasons, Schedule S does not allow it to "properly characterize the relationship between [its] two orbital configurations."
The FCC should insist that "SpaceX adhere to the well-settled framework under Part 25—namely, that licensees submit an application for a single system," Amazon argued.

          
                  