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Space Exploration Technologies Corp.’s (SpaceX) request to change its Starlink satellite altitudes has been approved by the Federal Communications Commission (FCC). The International Bureau (IB) adopted the modification last week, but it publicly revealed the decision today. This adoption comes after SpaceX was granted partial authority to launch satellites in polar orbit in January, as the company asked the FCC to partially grant a portion of its request due to the difficulty of placing spacecraft above remote regions.

In a similar vein, the Bureau replied to Kuiper’s arguments that since SpaceX will lower its ground station elevation angles, more satellites will be visible. This will increase interference as Kuiper satellites will also be in the ground stations’ operating ‘cone’ (the area in the sky visible to each station).

In response, SpaceX had argued that while the potential for interference resulting from this change will increase, the overall interference from the modification will drop since it will also lower Starlink satellite altitudes. The Bureau concurs with this line of argument, as it states in the public order that:

The order also highlights how SpaceX’s concession to accept interference from Kuiper resulted in its modification request being granted. In several FCC filings, SpaceX agreed that due to the modification, more of its system would be susceptible from interference by Kuiper, and it assented to accept this interference.

This did not go unnoticed by the Bureau, who comments:

DISH produced multiple analyses showing that if SpaceX were to violate this commitment, it would create significant interference for DISH’s systems.

DISH then produced another analysis using what it termed as real-world parameters to demonstrate that even if Starlink adhered to a Nco of 1, it would still end up interfering with DISH terminals. The company concluded its arguments by requiring the FCC to mandate SpaceX to share data with DISH to allow the latter to determine its operating environment accurately. These arguments came alongside a demand that SpaceX modifies its Starlink license to explicitly agree to a Nco of 1 and limit itself to future FCC rulings.

At this point, SpaceX’s director of satellite policy, Mr. David Goldman, in a masterstroke, agreed to modify Starlink’s license to explicitly state that SpaceX would stick to a value of one for Nco. This concession proved crucial in Mr. Goldman’s company securing approval for the third modification, as the IB notes:

The Bureau has also rejected DISH’s demands for more data and that Starlink be explicitly required to accept future revisions in the criteria chosen by the FCC to determine interference.

Another concern raised by commentators regarding the modification request was the potential for space debris. At this front, the IB will require SpaceX to submit a semi-annual report highlighting the number of potential collision events identified, satellites removed from operation due to a collision risk, satellites that entered the Earth’s atmosphere and satellites that are not responding to ground monitoring. SpaceX is also now required by the Commission to report if the number of unresponsive satellites is equal to or greater than three in a year. This report is separate from the semi-annual requirement stated above.

Finally, commenting on whether Starlink blocking astronomers’ line of sigh requires an Environmental Assessment, the Bureau notes:

. . .Accordingly, we will continue to monitor this situation and SpaceX’s efforts to achieve its commitments in this record.