April 17, 2020 – Space Exploration Holdings, LLC – SpaceX – has filed an application with the FCC’s International Bureau asking for permission to modify its current FCC authorization to operate its Starlink satellite network at lower altitudes. In the filing, SpaceX summarized its request as follows:

Space Exploration Holdings, LLC seeks to modify its Ku/Ka-band NGSO license to relocate satellites previously authorized to operate at altitudes from 1,110 km to 1,325 km down to altitudes ranging from 540 km to 570 km, and to make related changes.

In March 2018, the FCC authorized SpaceX “to construct, deploy, and operate a proposed non-geostationary orbit (NGSO) satellite system comprising 4,425 satellites for the provision of fixed-satellite service (FSS) around the world.” The Starlink satellites will utilize Ku-Band (downlink/space-to-earth), Ka-Band (uplink/earth-to-space), and V-Band spectrum.

In April 2019, the FCC authorized SpaceX “to slightly reduce the number of satellites in [its Starlink] constellation, to operate a substantial portion of these satellites at a lower orbital altitude than previously authorized, and to include the use of Ku-band gateway earth stations for fewer than 75 of these lower-altitude satellites.” Specifically, the FCC authorized, subject to certain conditions, SpaceX to reduce the number of satellites in its Starlink constellation from 4,425 to 4,409; relocate 1,584 satellites authorized to operate at an altitude of 1,150 km to operate at an altitude of 550 km; and make related changes to the operations of its Starlink satellites

In its April 17, 2020 application, SpaceX is seeking permission to operate all 4,400 of its planned Starlink satellites at altitudes ranging from 540 km to 570 km.

SpaceX has advocated for the ability to deploy satellites at lower altitudes to help prevent space debris. SpaceX included the following in comments filed in 2018 in the FCC’s space debris proceeding:

As the Commission correctly observed, the atmospheric drag of altitudes closer to the Earth make them effectively self-cleaning with regard to debris and therefore generally safer for spacecraft operation. In fact, this quality led SpaceX to file a modification to its authorization to lower 1,584 of its satellites to an operational altitude of 550 km. At this altitude, SpaceX can actively deorbit its spacecraft within weeks, but even in the unlikely event that an individual satellite fails, the atmospheric drag would lead to passive demise within months, leaving the orbit cleaner and safer.[1]

SpaceX announced its plans for the Starlink network in 2015. SpaceX will manufacture, launch, and operate the global network of low Earth orbit communications satellites, with the goal of providing Internet access services in the U.S. and worldwide. SpaceX has already received approval from the ITU and the FCC for 12,000 satellites, which would be the world’s largest low-Earth-orbit satellite constellation. It initially launched 60 Starlink satellites into orbit in May 2019, and currently has over 350 deployed. The next launch of Starlink satellites is scheduled for April 22, 2020.

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[1] Comments Of Space Exploration Technologies Corp., IB Docket No. 18-313, p. 19 (filed Apr. 5, 2019).