The best way of measuring short-term interference between non-geostationary orbit satellite systems is by looking at the absolute change in link availability, rather than a relative change in unavailability, according to SpaceX. In a docket 21-456 filing Monday, it submitted a 42-page technical study of spectrum sharing among NGSO systems that it said could help inform the FCC in setting a framework for assessing compatibility of earlier and later processing round satellite systems. It said 99% link availability without the interferer should be treated as the minimum benchmark for an efficient, well-designed NGSO system that warrants levels of protection without unduly empowering inefficient earlier-round systems.

SpaceX won't own the direct-to-device marketplace, due to the complexities and dependencies around regulation, spectrum uses and mobile value chains, Analysys Mason's Chris Baugh blogged Monday. However, SpaceX is leading the race to provide D2D commercial service, he noted. Baugh said that while SpaceX has indicated it plans to launch D2D service in Q4, that rollout will likely start in northern regions as did the Starlink broadband rollout. He said SpaceX could provide continuous coverage in the northern continental U.S. with 300 satellites, though southern U.S. coverage would be spotty. He said 800 satellites would likely provide 18/7 Mbps peak channel speeds for all user equipment in a beam area.

Eutelsat/OneWeb is warning the FCC that applicants in the second Ka-/Ku-band processing round and their pending applications are about to become effectively first-round systems. In a docket 21-456 filing Friday recapping meetings with FCC Commissioner Brendan Carr and aides to the other commissioners, Eutelsat/OneWeb said most of those second-round applications are pending. It said that if they're not approved this month, those second-round applicants won't have to deploy satellites before the interference protections sunset for the first processing round's satellites. That effectively makes those second-rounders first-round systems, it said. Eutelsat/OneWeb said the FCC's 2023 order doesn't explain why existing operators received a three-year reduction of their interference protections, from 10 to seven years, in 2023's non-geostationary orbit satellite spectrum sharing order. Eutelsat/OneWeb said the "inequitable" seven-year sunset exacerbates post-sunset spectrum sharing uncertainty. It said that after the sunset date, the FCC should require that only later-round systems that have fully deployed can enjoy co-equal sharing with first-round systems. OneWeb has a pending reconsideration petition for the sunset provisions in the 2023 order (see 2307210037).

The FCC Space Bureau signed off on launch and operation of Sirius XM's planned replacement geostationary orbit satellite digital audio radio service satellites, SXM-9 and SXM-10 (see 2304070003), the agency said in a pair of approvals last week. The company said it was planning a 2024 launch of SXM-9 and 2025 for SXM-10.

Both EchoStar and SpaceX are pointing to the record on SpaceX's reconsideration petition concerning the out-of-band power flux density limit in March's supplemental coverage from space order as backing their opposing positions. There is ample opposition to the recon petition in the record, EchoStar said in a filing posted Tuesday in docket 23-65. SpaceX's lone supporter, T-Mobile, is partnering with it on SCS service and the carrier misunderstands how notice-and-comment rulemaking works, EchoStar said. The FCC wasn't obliged to put on notice in the SCS NPRM that it might adopt an aggregate out-of-band emissions limit, it added. SpaceX said the technical evidence in the record shows the need to reconsider the aggregate power limits. Band-specific limits "would respect fundamental physics," and there's no technical evidence supporting the arguments of backers of the aggregate limit, it said.

SpaceX is moving its headquarters from Hawthorne, California, to Starbase, Texas, near Brownsville, founder Elon Musk posted Tuesday on X. Various laws in California "attacking both families and companies" prompted the move, Musk said. He said "the final straw" was Gov. Gavin Newsom (D) signing into law on Monday AB-1955, which prohibits requiring that K-12 teachers notify families about students' gender identity changes.

Creating a mission authorization framework for novel space activities would be "an excellent start" to address friction points those novel activities face when seeking regulatory approval, Deloitte said Monday. Such a framework would likely include a single agency or set of agencies as the mission approval authority for new activities, it said. "But more is required to be truly agile," Deloitte added, advocating for nonbinding "soft law tools" such as guidelines or norms. It urged creating multi-stakeholder "mission owner" groups that could include regulators and the private sector, fostering collaboration and experimentation. It also called for a space industry "regulatory playbook" that helps companies understand the space industry sector and details getting started.

A set of SpaceX's Starlink satellites that deployed at a too-low altitude don't pose a threat to other satellites or public safety, the company posted Friday on X. It said the Starlinks will burn up upon re-entering the atmosphere. A second-stage engine on one of its Falcon 9 rockets didn't complete its second burn, resulting in the deployment at the lower orbit, SpaceX said. In addition, the satellites' ion thrusters weren't sufficient to raise them to the higher altitude.

The U.S. Court of Appeals for the D.C. Circuit rejected Dish Network and International Dark-Sky Association (IDSA) arguments seeking a reversal of the FCC's OK of SpaceX's second-generation satellite constellation. In a 21-page opinion Friday (consolidated dockets 22-1337 and 23-1001), the three-judge panel said the FCC decision was "lawful and reasonably explained." Oral argument was in December (see [Ref;2312110031]). Pointing to Dish's challenge of the way SpaceX conducted its power flux-density limits testing, the judges said the commission's rules don't specify how an applicant must group its data. Moreover, Dish's evidence that a different grouping of the data shows SpaceX's system would exceed PFD limits "falls well short of a smoking gun that would require the FCC to disregard SpaceX’s self-certification," they said. Pointing to IDSA arguments that the FCC shouldn't have licensed the second-gen system without an environmental review, the court said the SpaceX license falls within the National Environmental Policy Act's categorical exclusion, so an environmental assessment is needed only if the FCC determines the license could have a significant environmental impact. The ruling said that the FCC "reasonably concluded" there wouldn't be any such impact. Deciding were Judges Neomi Rao, Michelle Childs and Douglas Ginsburg, with Rao penning the order. Nowhere does the decision cite or reference the Supreme Court's recent Loper Bright decision (see 2406280043), which ended the Chevron doctrine of courts largely deferring to federal agencies' expert decisions; nor does it cite Chevron.

The North Atlantic hurricane season and other extreme ocean weather will likely become more problematic for satellite-delivered maritime connectivity as climate change's impacts increase, Valour Consultancy blogged Wednesday. While L-band services should continue working properly, high-throughput applications using higher wavelengths such as Ku and Ka are more prone to weather-related disruption, it said. Adaptive power control and adaptive modulation can help but aren't silver bullets, Valour said. Maritime operators should plan for this, incorporating AI functions onboard so that slower satellite bands can fill in when higher wavelengths suffer from weather-related issues, it added.