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SpaceX’s Application For 30,000 Extra Starlink Satellites Highlights Concerns About Regulation

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A proposal from SpaceX for an additional 30,000 satellites in its Starlink constellation has raised concerns about how the company plans to operate the constellation, ahead of its planned start of service in 2020.

On Monday, October 7 the California-based company submitted 20 filings to the International Telecommunication Union (ITU) through the Federal Communications Commission (FCC) for the thousands of additional satellites. The ITU is responsible for allowing satellites to communicate and operate on specific frequencies while orbiting Earth.

SpaceX’s filings would add to the 12,000 satellites already planned by the company to encircle the globe and beam high-speed internet to any location on Earth, totaling 42,000. These additional satellites would be placed in orbits from between 328 and 580 kilometers above Earth, reported SpaceNews.

Currently SpaceX has plans to orbit satellites in its final constellation as high as 1,150 kilometers, where orbital decay rates could leave any defunct satellites in orbit for thousands of years. Each Starlink satellite weighs in at about 225 kilograms, equipped with communications equipment, thrusters, and a sizeable solar panel for power.

SpaceX launched its first batch of 60 Starlink satellites in May 2019, but almost immediately faced criticism. First, the company was accused of adding significantly to the space junk problem, and in September 2019, a European Space Agency (ESA) satellite was forced to dodge out of the way of one of SpaceX’s Starlink satellites.

Astronomers also expressed dismay at the impact the constellation would have on astronomical observations, both in visual and radio wavelengths owing to the transmissions of each satellite. SpaceX has sought to address the former by painting the bottom of each satellite black, the company noted in an email – although the solar panels would still reflect sunlight.

But several experts and companies have raised concerns about how SpaceX is handling the growth of its Starlink constellation. In relation to the recent filings, Luxembourg-based satellite operator SES said on Tuesday, October 15 that SpaceX was trying to avoid limits on how much communications' interference its satellites can cause to others, known as Equivalent Power-Flux Density (EPFD) limits.

“SpaceX is attempting to evade the single-entry EPFD limits for its satellite network by dividing the network into multiple parts and asking the ITU to evaluate them separately,” SES says.

Satellites in non-geostationary-satellite orbits (NGSOs) like Starlink can cause interference to higher GSOs by taking up some of the frequency spectrum needed to communicate with Earth. Such interference can prevent communications between GSOs and the ground, for example causing a loss of signal to users watching a show on TV.

One source familiar with the matter, who asked to remain anonymous, notes that SpaceX’s latest batch of 20 filings would enable it to subvert limits on interference that their satellites could cause. By increasing the number of unique filings SpaceX has access to, the amount of interference SpaceX could cause to GSOs essentially increases.

“Mega constellations are using the same spectrum as geostationary satellites, and as such, they have the potential to cause interference or interrupt their services,” the source says. “Regulations say that a constellation can only cause so much interference. But the ITU only says that ‘per filing’. So if I have many filings, I get an allotment of interference for each filing.”

Another way to describe it is in terms of carbon emissions. If a factory is only allowed to emit a certain amount of carbon per year, a company could sidestep these laws by saying their single factory is in fact 20 factories, meaning they are “therefore allowed to emit 20 times the carbon”, says the source.

SES also says that by submitting so many filings recently, and frequently changing the plans for its service, SpaceX has bogged down the ITU with paperwork, causing a backlog that would prevent the ITU from processing their filings before SpaceX had launched most of its Starlink satellites, which it plans to do in the coming years, enabling them to operate without any additional regulation.

“Because SpaceX keeps moving the goalposts, SES and other GSO [geosynchronous satellite] operators have no assurance that there will be a definitive ITU finding any time in the near future on the SpaceX system as it is actually being operated,” they write.

“Assuming it takes the ITU two to four months on average to review each filing, even if it started immediately, the ITU would not complete its findings regarding the whole set of SpaceX filings until some time between early 2023 and the middle of 2026.”

Tim Farrar, president of satellite consulting and research firm TMF Associates in California, says that SpaceX has an “ulterior motive” for submitting its filing for an additional 30,000 satellites. He says that SpaceX can start operating its Starlink system before the ITU has made a decision on the filings, whereas other companies have had to wait for ITU approval before they started their own commercial services.

“The FCC has given permission to SpaceX to go and operate regardless while it's under consideration,” he says. “SpaceX is pushing forward extremely aggressively. I think there’s going to be continuing protests not just from their rivals, but more active concerns from other geostationary satellite operators.”

SpaceX for its part said in its email that the latest filing was intended to “responsibly scale Starlink’s total network capacity and data density to meet the growth in users’ anticipated needs.” The company hopes to start offering its Starlink service to customers in the Nothern U.S. and Canada as early as next year, once they have completed 24 launches.

The next batch of Starlink satellites is expected to launch later this month, with another three launches possible before the end of the year. This suggests SpaceX is planning a rapid increase of Starlink launches, with a further 20 needed in 2020 to begin their operations as planned, likely totalling more than 1,000 satellites.

SpaceX is not the only company planning a mega constellation to provide global high-speed internet services anywhere on Earth. Other companies include OneWeb and Amazon, the former of which has already launched satellites of its own, and the latter of which is currently working to get the licenses needed for launch and operation.

However, it is the sheer pace and scale of SpaceX’s constellation – OneWeb are planning for only 650 satellites, for example – that is causing some concern. Aside from collision risks and negative effects on astronomy, it now appears that the communications interference resulting from the constellation could also be an important issue.

“This is one of the key problems when it comes to regulating constellations,” said Luc Riesbeck, a researcher at the Space Policy Institute at George Washington University. “There are (currently) very few milestones or stepping off points – it’s just all at once licensing. Regulators and operators should be striving for sustainable and safe architectures wherever they can.”

SpaceX did not immediately reply to a request for comment on the issues raised by SES.

This article has been updated to clarify the difference between SES' comments on altering the Starlink service and SpaceX's filing for 30,000 additional satellites.

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