Partial FCC grant weakens SpaceX Starlink Gen2 constellation

Friday, December 2, 2022 | Chimniii Desk

After more than two and a half years, the US Federal Communications Commission (FCC) has finally granted the company a license, but only after drastically decreasing its scope. The first FCC license application for Starlink Gen2 was filed in May 2020. The Starlink Gen2 application was amended in the second half of 2021. The final review process began after the FCC accepted the Gen2 application from SpaceX. The FCC granted permission to launch just 7,500 of the Starlink Gen2 satellites it had requested permission for more than 30 months before.

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The FCC didn't explain how it arrived at its 75% reduction or why the number is slightly lower than a different constellation. Adding insult to injury, the FCC acknowledges that the total number of satellites authorized to be deployed is not increased by our action today, and in fact is slightly reduced. There are 4 and 5 bed homes with grand decks in a 17 acre development. 5 million dollars + at Mumbai. That claimed reduction is thanks to the fact that shortly before this decision, SpaceX told the FCC in good faith that it would voluntarily avoid launching the dedicated V-band Starlink constellation it already received a license for.

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Once Starlink Gen2 was approved, it would request permission to add V-band payloads to a subset of the planned Gen2 satellites. The FCC limited the number of Starlink Gen2 satellites permitted to less than the number of satellites approved by the FCC in November of last year. The FCC's partial grant barely mentioned SpaceX's detailed plans to use new E-band antennas on Starlink Gen2 satellites and next-generation ground stations, just stating that it will "defer acting on" the request until further review and coordination with Federal users.

The Starlink Gen2 satellites can only be launched at altitudes between 525 and 535 kilometers. The FCC decided to drastically downscale the Starlink Gen2 constellation in order to evaluate the complex and novel issues on the record before, raising the question of what exactly the Commission was doing in the 30 months since. Less than five months after applying, the company received a full license for its V-band constellation.

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The first megaconstellation ever reviewed by the FCC, the 4,408-satellite Starlink Gen1 constellation, was licensed 16 months after its first application and eight months after a modified application was submitted. Adding to the unusual and inconsistent decision-making in this FCC ruling, the Commission openly acknowledges that the idea to grant SpaceX permission to launch a fraction of its Starlink Gen2 constellation came from Amazon.

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The public interest would be served by taking this approach in order to permit monitoring of developments involving this large-scale deployment and allow additional consideration of issues unique to the other requests, according to the FCC. The V-band Starlink constellation was approved by the FCC for over 7,000 satellites. The FCC gave permission for 2,814 satellites to be flown in the Starlink constellation. The consequences of space debris, which would last hundreds of years at 1000+ kilometers, became more conscious of by the time of the request for permission to launch those 2,814 satellites to around 550 kilometers. The change was fully approved by the FCC in April 2021.

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The FCC says that there are unique issues that need to be considered for Starlink Gen2 satellites that are between 604 and 614 kilometers. Starlink satellites are expected to be four times heavier and feature a larger surface area, but the fact remains that the FCC has already granted permission to launch almost 3000 smaller satellites to orbits much higher than 604 kilometers. The Commission's claims that a partial license denial was justified by concerns about orbital debris and space safety are incoherent at best.

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A number of Starlink Gen2 prototypes have been built by the company. The decision by the FCC to subject SpaceX to an arbitrary metric devised by another third-party, for-profit company is the strangest part of the partial grant. The number of years each failed satellite remains in the air, summed across all failed satellites, was proposed in a March 2022 letter. The FCC adopted the arbitrary limit of 100 object years as a condition of its Starlink Gen2 authorization. Once the sum of the time required for all failed Starlink Gen2 satellites to naturally deorbit reaches 100 years, the FCC will force SpaceX to cease satellite deployment.

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The FCC acknowledges that failure of just 20 Starlink satellites would force the company to stop launches. The Commission doesn't explain how it will decide when Starlink can be launched again. The company's license could be revoked if it doesn't deploy 3,750 Starlink Gen2 satellites by November 2028 and all 7,500 satellites by November 2031. If this rule were applied to other constellations, there would be more than 30 failed Starlink Gen1 satellites at or close to their operational altitudes, meaning that if this rule were applied to other constellations, there would be more than 30 failed Starlink Gen1 satellites at or close to their operational OneWeb had a single satellite fail at 1200 kilometers in 2021.

It will take hundreds of years to deorbit at that altitude. The FCC makes it clear that it will consider changing those restrictions and allowing more of the Starlink Gen2 constellation to be launched in the future. The Commission has shown that it will happily take years to modify existing licenses or approve new ones, which is not a reassuring foundation for investments as large and precarious as megaconstellations. Short of shady handshake deals in back rooms, the FCC's partial grant leaves the Starlink Gen2 constellation in an undesirable position.

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It could be forced to redesign its satellites and ground stations to avoid the E-band, or it could continue to build and deploy satellites and ground stations with E-band antennas without a guarantee that it will ever be able to use that hardware. There is no guarantee that the FCC will allow SpaceX to launch any of the 22,500 satellites left on the table by the partial grant, which will drastically change the financial calculus that determines whether the constellation is economically viable and how expansive associated infrastructure needs to be.

Starlink Gen2 would be stuck with zero polar coverage if the FCC fails to approve the expansion of the constellation. Assuming an unprecedentedly low $1-2M to build and launch each 50-150 Gbps satellite, Starlink Gen2 is likely to represent an investment of at least $30-60 billion. With its partial license denial and the addition of several new and arbitrary conditions, the FCC is forcing SpaceX to take an even riskier gamble with the billions of dollars of brand new infrastructure it will need to build to manufacture, launch, operate, and utilize its Starlink Gen2 constellation.

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