October 27, 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-20170301-00027, SAT-LOA-20200526-00055, and SAT-

AMD-20210818-00105

Dear Ms. Dortch:

As a part of its fundamental commitment to space sustainability, SpaceX has worked

extensively and collaboratively with federal agencies and the scientific community to establish
and implement best practices designed to preserve space and our environment for future
generations. SpaceX will continue this collaboration as it deploys its second-generation (“Gen2”)
constellation, which will bring even higher quality satellite broadband to people, businesses, and
community anchor institutions across the country and around the world.

Throughout this proceeding, SpaceX has shown that the National Environmental Policy
Act does not apply to activities in space. 1 But in an abundance of caution and without waiving its
position, SpaceX has also submitted into the record multiple independent studies that demonstrate
the atmospheric effect of alumina formed during Gen2 satellite reentry will be negligible or
nonexistent. 2 By contrast, Viasat and its recruits have entirely failed to substantiate their baseless
environmental claims against SpaceX’s Gen2 constellation, falling well short of their burden to
“set[] forth in detail” why the Gen2 system presents a plausible risk of substantial environmental
harm, or to overcome the Commission’s categorical exclusion of satellite licensing from
environmental review. 3 For these reasons, Viasat’s and its recruits’ unsupported speculations
about the environmental impacts of alumina formed by reentering Gen2 satellites simply have no
legal import to this proceeding.

Even so, SpaceX remains committed to leading the way on space sustainability, and
recognizes that further dialogue with the scientific community on this issue would be valuable.
For instance, the U.S. Government Accountability Office hypothesized that additional

1
See Letter from Jameson Dempsey to Marlene H. Dortch, IBFS File Nos. SAT-LOA-20200526-00055 and SAT-
AMD-20210818-00105 (Oct. 20, 2022) (“SpaceX October 20 Letter”); Letter from Jameson Dempsey to Marlene
H. Dortch, IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105 (Sept. 21, 2022);
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 43-58 (Feb. 24, 2022).
2
See SpaceX October 20 Letter at 3-5.
3
See id. at 2-5.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
October 27, 2022
Page 2 of 2

“observational data” on the release of alumina from satellite reentry could help the scientific
community better quantify emissions and develop “more accurate atmospheric modeling studies.” 4
To that end, SpaceX commits to work with the scientific community to explore methods to collect
observational data on the formation of alumina from satellite reentry. SpaceX will implement
reasonable methods that are discovered to the extent practicable and will report findings from these
measurements to the Commission.

Additionally, SpaceX hereby notifies the Commission of its intent, following issuance of
the Gen2 license, to seek a modification of its V-band authorization 5 to significantly reduce the
total number of satellites ultimately on orbit. SpaceX plans to request Commission authorization
to (1) harmonize the orbital parameters of those V-band space stations with those requested in
SpaceX’s pending second-generation (“Gen2”) application 6 and (2) confirm that these V-band
space stations will be operated as payloads onboard a subset of SpaceX’s proposed Gen2 satellites,
and not as separate spacecraft. This modification will not increase, and may slightly reduce, the
number of V-band space stations and it will not materially affect any other aspects of the V-band
license. SpaceX does not anticipate that this change to its planned V-band operations will alter
any material aspect of its pending application to deploy and operate Gen2 space stations in the Ku-
, Ka-, and E-bands.

Finally, SpaceX recently submitted combined EPFD data files to the Commission for its
entire Gen2 system. SpaceX confirms that such files, when analyzed with the ITU-approved
validation software, comply with the applicable EPFD limits.

Sincerely,
/s/ David Goldman
David Goldman
Director, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, N.W.
Suite 475
Washington, DC 20004

4
U.S. Government Accountability Office, Large Constellations of Satellites: Mitigating Environmental and Other
Effects, GAO-22-105166, at 16 (Sep. 29, 2022) (“GAO Report”), https://www.gao.gov/products/gao-22-105166.
5
See Space Exploration Holdings, LLC, Memorandum Opinion, Order and Authorization, 33 FCC Rcd. 11434
(2018); Application for Satellite Space Station Authorizations, Stamp Grant, IBFS File No. SAT-LOA-20170301-
00027 (issued June 9, 2020).
6
Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operating Authority for
the SpaceX Gen2 NGSO Satellite System, Application, IBFS File No. SAT-LOA-20200526-00055 (filed May 26,
2020); Space Exploration Holdings, LLC, Amendment to Pending Application for the SpaceX Gen2 NGSO
Satellite System, Amendment, IBFS File No. SAT-AMD-20210818-00105 (filed Aug. 18, 2021).