Page 1 Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. In the Matter of
Space Exploration Holdings, LLC
Request for Modification of the Authorization for
the SpaceX NGSO Satellite System
)
)
)
)
)
)
File No. SAT-MOD-20190830-Call Signs S2983 and S
REPLY OF SES AMERICOM, INC. AND O3B LIMITED
SES Americom, Inc. and its affiliate O3b Limited (collectively, “SES”) submit this reply
regarding the above-captioned application of Space Exploration Holdings, LLC (“SpaceX”) to
modify its license for a Ku/Ka-band non-geostationary orbit (“NGSO”) satellite system by
adjusting the orbital spacing. 1 The SES petition to defer the Application explains that SES
entities operate both NGSO and geostationary orbit (“GSO”) satellite networks that use these
bands and asks the Commission to take steps to ensure that SpaceX’s proposed changes will not
adversely affect other NGSO or GSO networks. As discussed below, the SpaceX response 3 fails to cure the Application’s deficiencies
regarding the effect of the voluntary SpaceX changes on the interference environment for O3b
and other authorized NGSO networks in the Ku- and Ka-band spectrum. With respect to
protection of GSO systems, SpaceX has provided additional data regarding its claims of
compliance with equivalent power flux-density (“EPFD”) limits set by the International
Space Exploration Holdings, LLC, File No. SAT-MOD-20190830-00087 (“Application”);
Space Exploration Holdings, LLC, 34 FCC Rcd 2526 (IB 2019) (“SpaceX Modification”); Space
Exploration Holdings, LLC, 33 FCC Rcd 33917 (2018) (“SpaceX Authorization”).
Petition to Defer of SES Americom, Inc. and O3b Limited, File No. SAT-MOD-2019083000087, filed Oct. 15, 2019 (“SES Petition”).
Consolidated Opposition to Petitions of Space Exploration Holdings, LLC, File No. SATMOD-20190830-00087, filed Oct. 30, 2019 (“SpaceX Opposition”).Page 2 Telecommunication Union (“ITU”), but SES has not yet had an adequate opportunity to review
and evaluate those materials. SES requests that the Commission continue to defer further
processing of the Application pending resolution of these important matters.
I.
SPACEX HAS NOT JUSTIFIED CONSIDERATION OF ITS
APPLICATION OUTSIDE A PROCESSING ROUND
The SES Petition notes that under the Commission standard set forth in the SpaceX
Modification decision, whether an NGSO system modification application is eligible for action
without initiating a new processing round depends on if the “modification would worsen the
interference environment,” 4 either by creating additional interference into other NGSO systems
or increasing the susceptibility of the applicant’s network to interference from other NGSO
systems. 5 Because the Application lacks a sufficient showing with respect to either of these two
essential components, the SES Petition urges the Commission to impose conditions on any grant
to ensure that the interests of O3b and other participants in the 2016 Ku/Ka-band NGSO
processing round are adequately protected. Specifically, SpaceX should be required to:
(1) alter its proposed operations to eliminate any increase in
interference to other NGSO systems resulting from the changes
sought in the Application and (2) accept any additional
interference from other NGSO networks due to SpaceX’s multiple
revisions of the constellation design the Commission approved in
the SpaceX Authorization. SpaceX opposes SES’s requested condition but fails to supply any supporting data to
demonstrate that the condition is unnecessary. SpaceX does not dispute SES’s observation that
“SpaceX’s own analysis shows that in some scenarios, the proposed changes would result in
SES Petition at 7 & n.15, quoting SpaceX Modification, 34 FCC Rcd at 2529, ¶ 9.
See SpaceX Modification, 34 FCC Rcd at 2531-32, ¶¶ 12-15.
SES Petition at 9. Page 3 slightly higher levels of interference to the O3b network.” 7 But SpaceX argues that in other
scenarios, the proposed changes would lessen interference to O3b, and that these decreases
“overwhelm” the increases in the interference-to-noise ratio with respect to O3b. 8 Maintaining
the interference environment, though, is not a matter of averaging out the pluses and minuses, as
the prospect that the risk of interference may be lower at some future time or stage of
deployment would not cancel out the adverse effects O3b would experience during times of
increased interference.
More critically, SpaceX provides nothing to fill the gaps in the Application regarding
whether the proposed changes would make the SpaceX network more vulnerable to interference
from other NGSO systems. The Commission has explicitly recognized that it “must examine”
any effects on interference susceptibility in order to determine whether a modification would
alter the operating environment. 9 SpaceX’s response is to argue that SES has not shown any
reason why the modification would make the SpaceX constellation more susceptible to
interference. 10 But that is not SES’s burden – instead, SpaceX bears responsibility for satisfying
the Commission that grant of the Application would not disrupt the equilibrium among NGSO
systems with respect to intersystem interference matters.
Given SpaceX’s failure to satisfy its obligation to demonstrate that its voluntary changes
would not change the interference environment, the condition language SES has requested is
clearly warranted to protect O3b and others with NGSO authority. SpaceX argues that the
Id. at 8 & n.17.
SpaceX Opposition at 7-8.
SpaceX Modification, 34 FCC Rcd at 2531, ¶ 14.
SpaceX Opposition at 8. Page 4 Commission should not “unbalance the scales . . . by imposing conditions only on SpaceX,” but it is SpaceX’s own decision to pursue multiple changes to its network that has upset the
balance among Ku/Ka-band NGSO processing round participants. Imposing the requested
condition language is the only way for the Commission to preserve the interference environment
and ensure that SpaceX bears the consequences of its voluntary changes and does not attempt to
shift those consequences to others.
As the SES Petition emphasizes, an express condition is preferable to the approach taken
in the SpaceX Modification decision, which identified ways that SpaceX could avoid receiving
increased interference from other NGSO systems due to lowering the orbital altitude for a
portion of its fleet, but did not explicitly require SpaceX to employ those measures. 12 By making
clear to SpaceX that its interference rights are based on the system design approved in the
SpaceX Authorization, the Commission can provide SpaceX the flexibility to innovate while
protecting other NGSO systems from having to accept more interference from SpaceX or from
being expected to alter their operations to accommodate changes that make SpaceX’s system
more susceptible to interference. 13 Far from unfairly singling SpaceX out, the condition language
set forth in the SES Petition presents the optimum solution to enable SpaceX to carry out its
planned changes without disadvantaging other networks.
Id.
See SES Petition at 9 & n.21, citing SpaceX Modification 34 FCC Rcd at 2531-32, ¶ 15.
The SES Petition notes that simply lowering the altitude of some SpaceX satellites to
550 kilometers from the originally authorized range of 1,110-1,325 kilometers could make those
spacecraft 6 to 8 db more sensitive to interference from O3b and other NGSO uplink
transmissions. SES Petition at 9-10 n.22. SpaceX does not dispute these calculations. Defining
SpaceX’s rights based on its original system license will prevent SpaceX from attempting to
force other NGSO systems to decrease their operating power to counteract the higher sensitivity
resulting from SpaceX’s design choices. Page 5 II.
SES REQUIRES ADDITIONAL TIME TO REVIEW
THE EPFD DATA SPACEX PROVIDED
The SES Petition explains that the information in the Application is insufficient to allow
SES to verify that SpaceX will comply with applicable EPFD limits, creating uncertainty for
both GSO and NGSO users of this spectrum. 14 This deficiency is particularly problematic given
the multiple changes SpaceX has proposed to its system, the backlog for ITU assessment of
EPFD showings, which has been worsened by SpaceX’s submission of twenty new ITU filings,
and the possibility of changes to the ITU’s EPFD evaluation software. To fully address this
concern, the Commission would need to reinstate the requirement included in the original
SpaceX Authorization and codified in Section 25.146(c) 15 that SpaceX await the completion of
ITU review before initiating service. At a minimum, the SES Petition asks the Commission to
require SpaceX to provide the PFD masks, EIRP masks, and inter-satellite masks necessary to
confirm compliance with EPFD limits and allow at least 30 days for review and further
comments once those materials have been provided.
Simultaneously with filing its opposition on October 30, SpaceX delivered to SES a disk
containing data relating to the EPFD calculations for the SpaceX network with the modifications
proposed in the Application. In the limited time it has had access to the information, SES has not
had an adequate opportunity to assess the adequacy and completeness of the files or perform its
own calculations of EPFD levels. The SES personnel who are qualified to undertake these tasks
are currently unavailable, as they are representing SES at the ongoing World Radio Conference
(“WRC”) in Egypt, which began on October 28. Accordingly, SES reserves the right to comment
SES Petition at 2-7.
47 C.F.R. § 25.146(c). Page 6 further on EPFD compliance matters once its personnel have returned from the WRC and are
able to complete an assessment of the data SpaceX provided.
III.
CONCLUSION
For the foregoing reasons, the Commission should defer further consideration of the
Application while SES evaluates the new information SpaceX supplied regarding its compliance
with EPFD limits and condition any grant of the Application to preserve the interference
environment for O3b and other NGSO systems.
Respectfully submitted,
SES AMERICOM, INC. AND O3B LIMITED
Of Counsel
Karis A. Hastings
SatCom Law LLC
1317 F Street, N.W., Suite Washington, D.C.
By: /s/ Petra A. Vorwig
Senior Legal and Regulatory Counsel
SES Americom, Inc.
1129 20th Street N.W., Suite Washington, D.C. By: /s/ Suzanne H. Malloy
Vice President, Regulatory Affairs
O3b Limited
1129 20th Street N.W., Suite Washington, D.C.
November 12, Page 7 CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of November, 2019, I caused to be served a
true copy of the foregoing “Reply of SES Americom, Inc. and O3b Limited” by first class mail,
postage prepaid, upon the following:
Patricia Cooper
Vice President of Satellite Government Affairs
David Goldman
Director of Satellite Policy
SPACE EXPLORATION TECHNOLOGIES CORP.
1155 F Street, N.W., Suite Washington, D.C.
William M. Wiltshire
Paul Caritj
HARRIS, WILTSHIRE & GRANNIS LLP
1919 M Street, N.W., Suite Washington, D.C.
/s/ Roxana Hernandez
PDF Page 1
PlainSite Cover Page
PDF Page 2
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
Space Exploration Holdings, LLC
Request for Modification of the Authorization for
the SpaceX NGSO Satellite System
)
)
)
)
)
)
File No. SAT-MOD-20190830-00087
Call Signs S2983 and S3018
REPLY OF SES AMERICOM, INC. AND O3B LIMITED
SES Americom, Inc. and its affiliate O3b Limited (collectively, “SES”) submit this reply
regarding the above-captioned application of Space Exploration Holdings, LLC (“SpaceX”) to
modify its license for a Ku/Ka-band non-geostationary orbit (“NGSO”) satellite system by
adjusting the orbital spacing. 1 The SES petition to defer the Application explains that SES
entities operate both NGSO and geostationary orbit (“GSO”) satellite networks that use these
bands and asks the Commission to take steps to ensure that SpaceX’s proposed changes will not
adversely affect other NGSO or GSO networks. 2
As discussed below, the SpaceX response 3 fails to cure the Application’s deficiencies
regarding the effect of the voluntary SpaceX changes on the interference environment for O3b
and other authorized NGSO networks in the Ku- and Ka-band spectrum. With respect to
protection of GSO systems, SpaceX has provided additional data regarding its claims of
compliance with equivalent power flux-density (“EPFD”) limits set by the International
1
Space Exploration Holdings, LLC, File No. SAT-MOD-20190830-00087 (“Application”);
Space Exploration Holdings, LLC, 34 FCC Rcd 2526 (IB 2019) (“SpaceX Modification”); Space
Exploration Holdings, LLC, 33 FCC Rcd 33917 (2018) (“SpaceX Authorization”).
2
Petition to Defer of SES Americom, Inc. and O3b Limited, File No. SAT-MOD-2019083000087, filed Oct. 15, 2019 (“SES Petition”).
3
Consolidated Opposition to Petitions of Space Exploration Holdings, LLC, File No. SATMOD-20190830-00087, filed Oct. 30, 2019 (“SpaceX Opposition”).
PDF Page 3
Telecommunication Union (“ITU”), but SES has not yet had an adequate opportunity to review
and evaluate those materials. SES requests that the Commission continue to defer further
processing of the Application pending resolution of these important matters.
I.
SPACEX HAS NOT JUSTIFIED CONSIDERATION OF ITS
APPLICATION OUTSIDE A PROCESSING ROUND
The SES Petition notes that under the Commission standard set forth in the SpaceX
Modification decision, whether an NGSO system modification application is eligible for action
without initiating a new processing round depends on if the “modification would worsen the
interference environment,” 4 either by creating additional interference into other NGSO systems
or increasing the susceptibility of the applicant’s network to interference from other NGSO
systems. 5 Because the Application lacks a sufficient showing with respect to either of these two
essential components, the SES Petition urges the Commission to impose conditions on any grant
to ensure that the interests of O3b and other participants in the 2016 Ku/Ka-band NGSO
processing round are adequately protected. Specifically, SpaceX should be required to:
(1) alter its proposed operations to eliminate any increase in
interference to other NGSO systems resulting from the changes
sought in the Application and (2) accept any additional
interference from other NGSO networks due to SpaceX’s multiple
revisions of the constellation design the Commission approved in
the SpaceX Authorization. 6
SpaceX opposes SES’s requested condition but fails to supply any supporting data to
demonstrate that the condition is unnecessary. SpaceX does not dispute SES’s observation that
“SpaceX’s own analysis shows that in some scenarios, the proposed changes would result in
4
SES Petition at 7 & n.15, quoting SpaceX Modification, 34 FCC Rcd at 2529, ¶ 9.
5
See SpaceX Modification, 34 FCC Rcd at 2531-32, ¶¶ 12-15.
6
SES Petition at 9.
2
PDF Page 4
slightly higher levels of interference to the O3b network.” 7 But SpaceX argues that in other
scenarios, the proposed changes would lessen interference to O3b, and that these decreases
“overwhelm” the increases in the interference-to-noise ratio with respect to O3b. 8 Maintaining
the interference environment, though, is not a matter of averaging out the pluses and minuses, as
the prospect that the risk of interference may be lower at some future time or stage of
deployment would not cancel out the adverse effects O3b would experience during times of
increased interference.
More critically, SpaceX provides nothing to fill the gaps in the Application regarding
whether the proposed changes would make the SpaceX network more vulnerable to interference
from other NGSO systems. The Commission has explicitly recognized that it “must examine”
any effects on interference susceptibility in order to determine whether a modification would
alter the operating environment. 9 SpaceX’s response is to argue that SES has not shown any
reason why the modification would make the SpaceX constellation more susceptible to
interference. 10 But that is not SES’s burden – instead, SpaceX bears responsibility for satisfying
the Commission that grant of the Application would not disrupt the equilibrium among NGSO
systems with respect to intersystem interference matters.
Given SpaceX’s failure to satisfy its obligation to demonstrate that its voluntary changes
would not change the interference environment, the condition language SES has requested is
clearly warranted to protect O3b and others with NGSO authority. SpaceX argues that the
7
Id. at 8 & n.17.
8
SpaceX Opposition at 7-8.
9
SpaceX Modification, 34 FCC Rcd at 2531, ¶ 14.
10
SpaceX Opposition at 8.
3
PDF Page 5
Commission should not “unbalance the scales . . . by imposing conditions only on SpaceX,” 11
but it is SpaceX’s own decision to pursue multiple changes to its network that has upset the
balance among Ku/Ka-band NGSO processing round participants. Imposing the requested
condition language is the only way for the Commission to preserve the interference environment
and ensure that SpaceX bears the consequences of its voluntary changes and does not attempt to
shift those consequences to others.
As the SES Petition emphasizes, an express condition is preferable to the approach taken
in the SpaceX Modification decision, which identified ways that SpaceX could avoid receiving
increased interference from other NGSO systems due to lowering the orbital altitude for a
portion of its fleet, but did not explicitly require SpaceX to employ those measures. 12 By making
clear to SpaceX that its interference rights are based on the system design approved in the
SpaceX Authorization, the Commission can provide SpaceX the flexibility to innovate while
protecting other NGSO systems from having to accept more interference from SpaceX or from
being expected to alter their operations to accommodate changes that make SpaceX’s system
more susceptible to interference. 13 Far from unfairly singling SpaceX out, the condition language
set forth in the SES Petition presents the optimum solution to enable SpaceX to carry out its
planned changes without disadvantaging other networks.
11
Id.
12
See SES Petition at 9 & n.21, citing SpaceX Modification 34 FCC Rcd at 2531-32, ¶ 15.
13
The SES Petition notes that simply lowering the altitude of some SpaceX satellites to
550 kilometers from the originally authorized range of 1,110-1,325 kilometers could make those
spacecraft 6 to 8 db more sensitive to interference from O3b and other NGSO uplink
transmissions. SES Petition at 9-10 n.22. SpaceX does not dispute these calculations. Defining
SpaceX’s rights based on its original system license will prevent SpaceX from attempting to
force other NGSO systems to decrease their operating power to counteract the higher sensitivity
resulting from SpaceX’s design choices.
4
PDF Page 6
II.
SES REQUIRES ADDITIONAL TIME TO REVIEW
THE EPFD DATA SPACEX PROVIDED
The SES Petition explains that the information in the Application is insufficient to allow
SES to verify that SpaceX will comply with applicable EPFD limits, creating uncertainty for
both GSO and NGSO users of this spectrum. 14 This deficiency is particularly problematic given
the multiple changes SpaceX has proposed to its system, the backlog for ITU assessment of
EPFD showings, which has been worsened by SpaceX’s submission of twenty new ITU filings,
and the possibility of changes to the ITU’s EPFD evaluation software. To fully address this
concern, the Commission would need to reinstate the requirement included in the original
SpaceX Authorization and codified in Section 25.146(c) 15 that SpaceX await the completion of
ITU review before initiating service. At a minimum, the SES Petition asks the Commission to
require SpaceX to provide the PFD masks, EIRP masks, and inter-satellite masks necessary to
confirm compliance with EPFD limits and allow at least 30 days for review and further
comments once those materials have been provided.
Simultaneously with filing its opposition on October 30, SpaceX delivered to SES a disk
containing data relating to the EPFD calculations for the SpaceX network with the modifications
proposed in the Application. In the limited time it has had access to the information, SES has not
had an adequate opportunity to assess the adequacy and completeness of the files or perform its
own calculations of EPFD levels. The SES personnel who are qualified to undertake these tasks
are currently unavailable, as they are representing SES at the ongoing World Radio Conference
(“WRC”) in Egypt, which began on October 28. Accordingly, SES reserves the right to comment
14
SES Petition at 2-7.
15
47 C.F.R. § 25.146(c).
5
PDF Page 7
further on EPFD compliance matters once its personnel have returned from the WRC and are
able to complete an assessment of the data SpaceX provided.
III.
CONCLUSION
For the foregoing reasons, the Commission should defer further consideration of the
Application while SES evaluates the new information SpaceX supplied regarding its compliance
with EPFD limits and condition any grant of the Application to preserve the interference
environment for O3b and other NGSO systems.
Respectfully submitted,
SES AMERICOM, INC. AND O3B LIMITED
Of Counsel
Karis A. Hastings
SatCom Law LLC
1317 F Street, N.W., Suite 400
Washington, D.C. 20004
By: /s/ Petra A. Vorwig
Senior Legal and Regulatory Counsel
SES Americom, Inc.
1129 20th Street N.W., Suite 1000
Washington, D.C. 20036
By: /s/ Suzanne H. Malloy
Vice President, Regulatory Affairs
O3b Limited
1129 20th Street N.W., Suite 1000
Washington, D.C. 20036
November 12, 2019
6
PDF Page 8
CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of November, 2019, I caused to be served a
true copy of the foregoing “Reply of SES Americom, Inc. and O3b Limited” by first class mail,
postage prepaid, upon the following:
Patricia Cooper
Vice President of Satellite Government Affairs
David Goldman
Director of Satellite Policy
SPACE EXPLORATION TECHNOLOGIES CORP.
1155 F Street, N.W., Suite 475
Washington, D.C. 20004
William M. Wiltshire
Paul Caritj
HARRIS, WILTSHIRE & GRANNIS LLP
1919 M Street, N.W., Suite 800
Washington, D.C. 20036
/s/ Roxana Hernandez
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