On August 9th 2024, David Goldman Vice President of Satellite Policy at SpaceX, submitted a petition to the Federal Communications Commission (FCC) initiating a rulemaking proceeding to revise regulations governing spectrum sharing between Low Earth Orbit (LEO) and Geostationary Orbit (GEO) satellite systems. The objective is to optimize spectrum utilization and foster innovation in the satellite industry. If new more efficient laws are adopted, SpaceX believe they can increase Starlink’s capacity per satellite by up to 8 times.
“Studies have already shown that these limits constrain NGSO capacity in Ku-band by eight times more than necessary to protect GSO operations.”
According to the company that owns Starlink, existing power restrictions for LEO satellite systems, known as Equivalent Power Flux Density (EPFD) limits adopted in 2000, were established in an era of significantly different technological capabilities. Starlink believe the outdated regulations hinder the deployment of advanced satellite systems and impede efficient spectrum use. Starlink emphasize that the current EPFD limits “are in need of a fresh technical review”.
However, Tim Farrar, a consultant in satellite communications and wireless spectrum, claims Starlink just wants “less restrictions” in order to primarily increase its capacity in the USA.
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Starlink know the FCC itself seeks to align these rules with the realities of today’s satellite technology. In its petition, Starlink heavily quoted the Commission’s own report. The FCC document dubbed “Working Document Towards a Preliminary Draft New Report” was released in April 2024.
April’s report builds upon FCC’s previous report titled “Revising Spectrum Sharing Rules for Non-Geostationary Orbit, Fixed-Satellite Service Systems” of 2023. FCC aims to modernize spectrum sharing for Non-Geostationary Orbit (NGSO) systems. Starlink claim these changes will address the limitations of the current GSO-NGSO sharing framework. If this happens the FCC will create a more dynamic and competitive satellite market
Moreover, the FCC itself has explained that these EPFD limits “represent the most constraining” regulatory restrictions imposed on non-GSO systems and directly degrade the efficiency of spectrum use by these systems.
“After all, you cannot just keep doing things the old way and expect to lead in the new.” FCC Chairwoman Jessica Rosenworcel stated in the NGSO Spectrum Sharing Order report.
SpaceX Want Updated Spectrum Sharing Rules
SpaceX, Co-founded by Elon Musk, want the FCC to initiate a rulemaking process to develop a modern, efficient GSO-NGSO spectrum sharing framework that won’t impose any unacceptable interference consequences on GSO systems.
SpaceX are targeting changes to Article 22 and Resolution 76 of the ITU Radio Regulations which contain spectrum sharing provisions. They claim these laws overprotect GSO fixed-satellite service (“FSS”) and GSO broadcasting satellite service (“BSS”) networks. Among other requirements, these rules impose strict EPFD limits on aggregate and single-entry interference from the transmissions of an NGSO system into GSO networks.
“The Commission should act now to update its NGSO-GSO spectrum sharing rules with respect to NGSO downlink operations, adopting a new domestic framework under Section 25.289 and Section 25.146 of the Commission’s rules for Article 22 bands below 30 GHz,” wrote SpaceX in the petition.
This rulemaking process will involve a comprehensive review of existing regulations and the development of new sharing methodologies that balance the interests of both LEO and GEO satellite operators. The framework should encourage investment in satellite technology and delivers benefits to consumers.
