SpaceX Voluntary Fur

October 4, 2022
BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554
Re: IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105
Dear Ms. Dortch:
SpaceX is excited to be on the cusp of deploying its second-generation (“Gen2”)

constellation, which will be the most advanced satellite system ever developed for delivering high-
speed, low-latency broadband connectivity to people throughout America and around the world.
SpaceX’s Gen2 system—like its separate Gen1 system—is particularly well-suited to rapidly
address the Commission’s fundamental broadband policy goals: closing the homework gap,
connecting remote and Polar regions, enhancing emergency preparedness and response, promoting
efficient use of spectrum, and serving as a model for efficient and sustainable use of orbital
resources.
SpaceX submitted a voluntary supplement on August 19, 2022, providing additional

information about its Gen2 system and responding to several questions from the International
Bureau staff. 1 To provide even more clarity on its plans and expedite resolution of the Gen2
application without conceding that such information is required or necessary to process the
application, or can properly form the basis of any license condition, SpaceX voluntarily provides
the following information to augment its earlier submission:
EPFD compliance across the Gen2 constellation. Using the ITU-approved validation
software, SpaceX has demonstrated that the Gen2 system will comply with the ITU’s equivalent
power flux-density (“EPFD”) limits, which the Commission has incorporated into its own rules. 2
The Commission relies on the ITU Radiocommunication Bureau to validate that analysis, 3
and thus has made clear that the Commission staff would not conduct its own independent
assessment of EPFD compliance, concluding “[w]e do not believe that such review is warranted
to reduce the likelihood that an incorrect submission is made to the ITU.” 4 In rejecting a challenge
to a prior authorization issued to SpaceX, the D.C. Circuit upheld the Commission’s refusal to
1
See Letter from David Goldman to Marlene H. Dortch, IBFS File Nos. SAT-LOA-20200526-00055 and SAT-
AMD-20210818-00105 (Aug. 19, 2022) (“Voluntary Supplement”).
2
Consolidated Opposition to Petitions and Response to Comments of Space Exploration Holdings, LLC, IBFS File
Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105, at Exhibit 1 (Feb. 24, 2022).
3
See 47 C.F.R. § 25.146(c).
4
Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters,
32 FCC Rcd 7809, ¶ 41 (2017).
Marlene H. Dortch
October 4, 2022
Page 2 of 6
depart from the ITU validation methodology to evaluate an alternative EPFD analysis precisely
because that is what the rules require.
The FCC must “adhere to its own rules and regulations.” AT&T Corp. v. FCC, 448
F.3d 426, 434 (D.C. Cir. 2006). Here, the governing rules require interference
between GSO and NGSO systems to be assessed through the method used in the
ITU-approved validation software. 47 C.F.R. § 25.146(a), (c)(2). DISH
acknowledges that SpaceX’s desired changes pass muster under that approach.
Nevertheless, DISH argues that its experts have a better method for calculating
interference. DISH thus faults the FCC for following its own interference rules.
But an agency “abuses its discretion when it arbitrarily violates its own rules, not
when it follows them.” BDPCS, Inc. v. FCC, 351 F.3d 1177, 1184 (D.C. Cir.
2003). 5
Accordingly, the Commission is on solid ground when it follows its rules, including its rule relying
on the ITU to make EPFD compliance determinations.
If the Commission were to depart from the ITU approach in this case—by, for example,
considering an analysis based on an aggregation of several EPFD data files that will be analyzed
individually for EPFD compliance by the ITU—it would abuse its discretion and violate its own
rules. Indeed, it would contradict its own conclusion “that the ITU is in the best position to
determine whether SpaceX appropriately relied on multiple ITU filings in its analysis.”6
Moreover, it would also establish a precedent that would open the door to competing alternative
EPFD analyses from interested parties in every case, thereby undercutting the efficiency and
consistency the current approach was designed to achieve. In addition, it would diverge from the
approach taken by other administrations for their own NGSO systems, including O3b and
OneWeb—neither of which have been asked by the Commission to provide aggregated EPFD
showings in connection with their market access applications. 7
Emergency beacons for non-U.S. operation. In the Voluntary Supplement, SpaceX

explained that some of the satellites in the Gen2 constellation will host a small radiofrequency
beacon for use in emergency communications and only outside of the United States. 8 While
SpaceX is not seeking U.S. market access for these beacons, it voluntarily attaches their specific
radiofrequency parameters as Exhibit A.
Further details for satellites in the Gen2 constellation. In its previous Voluntary
Supplement, SpaceX described the inputs used for its Debris Assessment Software (“DAS”)
analysis of the Gen2 satellites, along with its methodology for reaching its results. 9 This
5
Viasat, Inc. v. FCC, No. 21-1123, 2022 WL 3694873, at *3 (D.C. Cir. Aug. 26, 2022).
6
Space Exploration Holdings, LLC, 36 FCC Rcd. 7995, ¶ 34 (2021).
7
O3b relies upon a combination of the O3B-A and O3B-B ITU network filings for its first-round NGSO system,
while OneWeb relies upon the L6 and L7A ITU network filings for its second-round NGSO system.
8
See Voluntary Supplement at 6 & n.17.
9
See id. at 2-4.
Marlene H. Dortch
October 4, 2022
Page 3 of 6
information enables the Commission to replicate SpaceX’s analysis and demonstrate that even
using extremely conservative inputs, satellites in the Gen2 constellation will meet the
Commission’s per-satellite collision probability thresholds using the latest version of DAS. To
provide further clarity, SpaceX attaches as Exhibit B physical dimensions, DAS results using the
latest version of the software (version 3.2.3), and sample DAS logs for the current designs of the
planned satellites in SpaceX’s Gen2 constellation. SpaceX provides this information for the
limited purpose of verifying that such satellites will meet NASA’s established per-satellite
thresholds, and not because they are required under any Commission rule, order, or policy
guidance. Indeed, the Commission’s rules expressly provide that “technically identical” satellites
“need not . . . have the identical physical structure or microelectronics.” 10 Instead, the legally
relevant parameters are those specifically required under Sections 25.114(c) and (d) of the
Commission’s rules, which set the contours of an operator’s license while permitting necessary
changes to address technological advances, supply chain issues, or steps to further improve the
resilience of satellites.
Physical coordination with other space stations. In its Voluntary Supplement, SpaceX
detailed its ongoing and productive efforts to physically coordinate its satellites with other
operators, including manned spacecraft. SpaceX has also explained the steps it takes to ensure
efficient and sustainable use of orbital resources, both in its Gen2 application and amendment, 11
as well as through public updates on its website. 12 SpaceX will proactively contact operators of
large constellations before they launch and as they mature in an effort to physically coordinate
operations. For all operators, SpaceX has and will maintain open lines of communication. As a
matter of responsible operations, SpaceX uses a conservative maneuver threshold an order of
magnitude more sensitive than the industry standard and offers to take maneuver responsibility for
potential approaches except in situations where other operators are better positioned to assume
such responsibility (e.g., when they are orbit raising or deorbiting through SpaceX’s operational
altitudes). SpaceX has also developed sophisticated collision avoidance agreements with many
other spacecraft operators to facilitate physical coordination for systems yet to begin deployment
and for systems already on orbit.
Orbital tolerance to accommodate uncertainty in the solar cycle. The Voluntary

Supplement described the scientific and practical basis for SpaceX’s request for its orbital
tolerances. 13 To provide additional clarity, while changes in atmospheric drag will affect different
shells to different degrees, SpaceX will endeavor to maintain the relative spacing between orbital
shells. In any event, SpaceX will continuously physically coordinate with any operators in nearby
or overlapping orbits.
10
Amendment of the Commission’s Rules to Establish Rules and Policies Pertaining to a Mobile Satellite Service
in the 1610-1626.5/2483.5-2500 MHz Frequency Bands, 9 FCC Rcd. 5936, ¶ 182 n.250 (1994).
11
See Application for Approval for Orbital Deployment and Operating Authority for the SpaceX Gen2 NGSO
Satellite System, IBFS File No. SAT-LOA-20200526-00055, Technical Attachment at 46-48 (May 26, 2020)
(“Gen2 Application”); Amendment, IBFS File No. SAT-AMD-20210818-00105, Technical Attachment at 17-18
(Aug. 18, 2021).
12
See SpaceX’s Approach to Space Sustainability and Safety, SpaceX (Feb. 22, 2022),
https://www.spacex.com/updates/#sustainability.
13
See Voluntary Supplement at 4-5.
Marlene H. Dortch
October 4, 2022
Page 4 of 6
Deployment details for satellites in the Gen2 constellation. SpaceX noted in its Voluntary
Supplement that it plans to deploy satellites into the Gen2 constellation at low altitude to confirm
that each one is operating nominally before raising the satellite to its operational altitude. 14 SpaceX
does not currently intend to deploy directly into its operational altitudes. Moreover, SpaceX does
not intend to include tension rods or spacers for its Starship-based Gen2 satellite deployments, but
may initially use tension rods and spacers for Gen2 satellite deployments on Falcon 9.
Propellant to accommodate maneuvers throughout all phases of Gen2 satellite missions.

SpaceX has gone to extraordinary lengths to design its Gen2 satellite constellation to promote
sustainable operations in space. As stated above, SpaceX uses a conservative maneuver threshold
an order of magnitude more sensitive than the industry standard, even though this conservative
approach requires a significant investment in sustainability and performance. Not only must
SpaceX invest in satellites that are more capable and perform more maneuvers that carry
considerable cost to SpaceX, but SpaceX leads by example through its willingness to proactively
deorbit satellites when it detects issues, rather than waiting for larger issues to develop. SpaceX
takes this most costly approach out of an abundance of caution to best preserve and protect low
Earth orbit and encourages other operators to follow this best practice. As SpaceX stated in its
Gen2 application, “[a]ll satellites will have sufficient propellant and capability to perform any
avoidance maneuvers required for all phases of the satellites’ mission.” 15 SpaceX has budgeted
sufficient propellant to accommodate approximately 5,000 propulsive maneuvers over the life of
a satellite, including a budget of approximately 350 collision avoidance maneuvers per satellite
over that time period. Using SpaceX’s semi-annual satellite reports for comparison, the average
SpaceX’s Gen1 satellite has conducted fewer than three collision-avoidance maneuvers every six
months over the last year, and it conducted these maneuvers predominantly to avoid debris from
the November 2021 Russian anti-satellite demonstration. Even under these anomalous conditions,
a 350-maneuver budget is extremely conservative.
Launch cadence to support rapid broadband deployment. SpaceX remains committed to

deploying its Gen2 constellation as quickly as possible to meet the growing needs of consumers
throughout the country for high-speed, low-latency broadband service. In the previous Voluntary
Supplement, SpaceX explained that it plans to launch satellites for its Gen2 constellation beginning
with its three 500-kilometer shells, followed by satellites in the lower-altitude shells. 16 Although
its specific launch cadence is being finalized, SpaceX anticipates launching satellites into the Gen2
constellation at a rate of at least once per week during 2023, with a more rapid cadence over time.
While the number of satellites per launch will vary depending on the launch vehicle used and
whether any other payloads are involved, SpaceX expects that launches will have approximately
twenty to sixty satellites on each Falcon 9 launch and approximately fifty to one hundred satellites
initially on each Starship launch, with a variable number of satellites per launch as Starship and
Falcon 9 capabilities develop over time.
14
See id. at 4.
15
Gen2 Application, Technical Attachment at 41.
16
See Voluntary Supplement at 4.
Marlene H. Dortch
October 4, 2022
Page 5 of 6
* * *
In SpaceX’s initial Gen2 application, filed two-and-a-half years ago, SpaceX included all
information required by the Commission’s rules. As the application remained pending, SpaceX
was required to begin the development of its Gen2 system. To do otherwise would have resulted
in years-long delays in providing high-speed internet to those who need it most. As SpaceX
developed the Gen2 system, it reasonably relied on the Commission’s rules, with the expectation
that the rules on the books would be those governing its system. Of course, SpaceX recognized
that the Commission could exercise its rulemaking authority to change its rules, but this would
have occurred in an open process in which SpaceX, and others, would have been provided with
notice and the opportunity to comment on proposed changes.
In this proceeding, SpaceX has provided a wealth of technical and operational information
about its Gen2 system, significantly beyond what the Commission’s rules specify. In some cases,
SpaceX provided information that the Commission previously found unnecessary or redundant,
such as specific physical parameters and design details, 17 as well as information outside of the
Commission’s jurisdiction, such as information about SpaceX’s extensive collaborations with the
astronomy community to limit the reflectivity of its satellites. Now, two-and-a-half years after
filing the Gen2 application and over a year since filing its amended application, the Bureau is
requesting yet more information beyond the scope of the Commission’s rules. SpaceX values
transparency with the Commission, but is concerned that this additional information, which no
other operator is required to provide, will be used as a basis for conditioning a grant of its
application.
Unfortunately, as a practical matter, SpaceX has little choice but to accede to these requests
despite these concerns or add further to the already significant delays in the processing of its
application. This would harm SpaceX, the American people, and those globally who will benefit
from the Gen2 system. Therefore, SpaceX voluntarily provides the above information only for
informational purposes in an effort to bring this long-running process to a close. SpaceX does not
concede that such information is necessary for the processing of its application. Similarly, there
is no legal basis by which the information provided in this or other voluntary supplements could
serve as the basis for a condition on the grant of its application. Where, as here, the Commission
made an affirmative decision that information is unnecessary, the Commission should not bypass
legal prerequisites through substantive licensing conditions that overstep Commission authority or
conflict with existing rules.
The Commission should be particularly wary of doing so in response to anticompetitive

requests from competitors such as those that have sought to avoid Commission oversight by
licensing overseas and now seek to abuse the Commission’s processes to obtain sensitive,
proprietary information from—and to impose invented, heightened requirements solely on—
American satellite operators. Finally, as the Supreme Court has recognized, though afforded wide
17
See Comprehensive Review of Licensing and Operating Rules for Satellite Services, 28 FCC Rcd. 12403, ¶ 89
(2013) (eliminating a number of space station application requirements, including the requirement to specify
spacecraft weight and dimensions, because they are “redundant or unnecessary”).
Marlene H. Dortch
October 4, 2022
Page 6 of 6
latitude in its supervision over communication by wire and radio, “the Commission was not
delegated unrestrained authority” 18 and the public-interest standard “is not to be interpreted as
setting up a standard so indefinite as to confer an unlimited power.” 19
With a complete record before it, the Commission should swiftly grant the Gen2
application, enabling rapid deployment of next-generation satellite broadband to American
consumers and businesses, no matter where they are.
Sincerely,
/s/ David Goldman
David Goldman
Senior Director, Satellite Policy
SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Tel: 202-649-2641
Email: David.Goldman@spacex.com
18
FCC v. Midwest Video Corp., 406 U.S. 649, 706 (1972).
19
FRC v. Nelson Bros. Bond & Mortgage Co., 289 U.S. 266, 285 (1933).
EXHIBIT B
SATELLITE DIMENSIONS AND DAS OUTPUTS
The tables below present information for the current form factors of SpaceX Gen2
satellites: two of which will be launched initially on Falcon 9 rockets and one that will be launched
on Starship. For convenience, these satellites are labeled satellites F9-1, F9-2, and Starship,
respectively. Note that to better reflect a non-maneuverable satellite in a tumbling deorbit a scaling
factor has been applied to the area-to-mass ratios used with NASA’s Debris Assessment Software
(“DAS”). Specifically, a factor of 0.5 has been applied to the two larger satellites and a factor of
0.516 has been applied for the smallest one. Following the tables, SpaceX includes sample logs
from its DAS analyses for each of the current Gen2 form factors.
Length Width Area DAS Area DAS Mass

(m) (m) Number (m2) (m2) (kg)
Solar Array F9-1 8.1 2.8 1 22.68
Bus F9-1 2.8 1.3 1 3.64
Total Area F9-1 26.32 30 303
Solar Array F9-2 12.8 4.1 2 104.96

Bus F9-2 4.1 2.7 1 11.07
Total Area F9-2 116.03 120 800
Solar Array Starship 20.2 6.36 2 256.94

Bus Starship 6.4 2.7 1 17.28
Total Area Starship 274.22 294 2000
B-1
DAS 3.2.3 SpaceX Gen2 303 kg bus
Passive Decay Large Debris Collision Probability Analysis
==============
Run Data
==============
**INPUT**
Space Structure Name = 535

Space Structure Type = Payload
Perigee Altitude = 535.000 (km)
Apogee Altitude = 535.000 (km)
Inclination = 33.000 (deg)
RAAN = 0.000 (deg)
Argument of Perigee = 0.000 (deg)
Mean Anomaly = 0.000 (deg)
Final Area-To-Mass Ratio = 0.0510 (m^2/kg)
Start Year = 2022.000 (yr)
Initial Mass = 303.000 (kg)
Final Mass = 303.000 (kg)
Duration = 7.000 (yr)
Station-Kept = False
Abandoned = True
Long-Term Reentry = False
**OUTPUT**
Collision Probability = 1.2571E-04

Returned Message: Normal Processing
Date Range Message: Normal Date Range
Status = Pass
==============
**INPUT**

B-4
RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**
B-5
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-6
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

B-7
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-8
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
B-9
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-10
Abandoned = True
**OUTPUT**

Status = Pass
B-11
DAS 3.2.3 Decay Time
**INPUT**
Start Year = 2022.000000 (yr)

RAAN = 0.000000 (deg)
Area-To-Mass Ratio = 0.051000 (m^2/kg)
**OUTPUT**
Orbital Lifetime from Startyr = 1.659138 (yr)

Time Spent in LEO during Lifetime = 1.659138 (yr)
Last year of Propagation = 2023 (yr)
Returned Error Message: Object reentered
09 25 2022; 18:50:40PM Science and Engineering - Orbit Lifetime/Dwell Time
**INPUT**
Start Year = 2023.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2024.000000 (yr)
B-12
RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2025.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2026.000000 (yr)

RAAN = 0.000000 (deg)
B-13
**OUTPUT**

**INPUT**
Start Year = 2027.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2028.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-14
**INPUT**
Start Year = 2029.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2030.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2031.000000 (yr)

B-15
RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2032.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-16
Passive Decay, Large Debris Collision Probability Analysis
==============
Run Data
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

B-17
RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**
B-18
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-19
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

B-20
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-21
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

B-22
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-23
Abandoned = True
**OUTPUT**

Status = Pass
==============
B-24
DAS 3.2.3 Demise Time
**INPUT**
Start Year = 2022.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2023.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2024.000000 (yr)

B-25
RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2025.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2026.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**
B-26
**INPUT**
Start Year = 2027.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2028.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-27
**INPUT**
Start Year = 2029.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2030.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2031.000000 (yr)

RAAN = 0.000000 (deg)
B-28
**OUTPUT**

**INPUT**
Start Year = 2032.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-29
Passive Decay Large Debris Collision Probability Analysis
==============
Run Data
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

B-30
RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Fail
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**
B-31
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-32
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

B-33
Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Pass
==============
**INPUT**

RAAN = 0.000 (deg)
B-34
Abandoned = True
**OUTPUT**

Status = Fail
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Fail
B-35
==============
**INPUT**

RAAN = 0.000 (deg)
Abandoned = True
**OUTPUT**

Status = Fail
==============
**INPUT**

RAAN = 0.000 (deg)
B-36
Abandoned = True
DAS 3.2.3 Decay Time
**INPUT**
Start Year = 2022.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2023.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-37
**INPUT**
Start Year = 2024.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2025.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2026.000000 (yr)

B-38
RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2027.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2028.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**
B-39
**INPUT**
Start Year = 2029.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2030.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-40
**INPUT**
Start Year = 2031.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

**INPUT**
Start Year = 2032.000000 (yr)

RAAN = 0.000000 (deg)
**OUTPUT**

B-41

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October 4, 2022

Re: IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105

Dear Ms. Dortch:

SpaceX is excited to be on the cusp of deploying its second-generation (“Gen2”)

SpaceX submitted a voluntary supplement on August 19, 2022, providing additional

Emergency beacons for non-U.S. operation. In the Voluntary Supplement, SpaceX

Orbital tolerance to accommodate uncertainty in the solar cycle. The Voluntary

Propellant to accommodate maneuvers throughout all phases of Gen2 satellite missions.

Launch cadence to support rapid broadband deployment. SpaceX remains committed to

The Commission should be particularly wary of doing so in response to anticompetitive

SPACE EXPLORATION TECHNOLOGIES CORP.

SATELLITE DIMENSIONS AND DAS OUTPUTS

Length Width Area DAS Area DAS Mass

Total Area F9-1 26.32 30 303

Solar Array F9-2 12.8 4.1 2 104.96

Solar Array Starship 20.2 6.36 2 256.94

Passive Decay Large Debris Collision Probability Analysis

Space Structure Name = 535

Collision Probability = 1.2571E-04

Space Structure Name = 535

Collision Probability = 1.7064E-04

Space Structure Name = 535

Collision Probability = 8.0780E-05

Space Structure Name = 535

Collision Probability = 2.7433E-05

Space Structure Name = 535

Collision Probability = 4.8945E-05

Space Structure Name = 535

Collision Probability = 3.4781E-05

Space Structure Name = 535

Collision Probability = 7.6127E-05

Space Structure Name = 535

Collision Probability = 1.5404E-04

Space Structure Name = 535

Collision Probability = 1.3212E-04

Space Structure Name = 535

Collision Probability = 1.4004E-04

Space Structure Name = 535

Collision Probability = 1.4870E-04

Start Year = 2022.000000 (yr)

Orbital Lifetime from Startyr = 1.659138 (yr)

Start Year = 2023.000000 (yr)

Orbital Lifetime from Startyr = 1.492129 (yr)

Start Year = 2024.000000 (yr)

Orbital Lifetime from Startyr = 1.097878 (yr)

Start Year = 2025.000000 (yr)

Orbital Lifetime from Startyr = 0.966461 (yr)

Start Year = 2026.000000 (yr)

Orbital Lifetime from Startyr = 1.056810 (yr)

Start Year = 2027.000000 (yr)

Orbital Lifetime from Startyr = 1.522245 (yr)

Start Year = 2028.000000 (yr)

Orbital Lifetime from Startyr = 3.531828 (yr)

Start Year = 2029.000000 (yr)

Orbital Lifetime from Startyr = 4.355921 (yr)