Emissions Limits in PCS G Block Mean Throttling D2D Coverage: SpaceX
The FCC's out-of-band emissions (OOBE) limits in the PCS G Block will particularly hurt direct-to-device (D2D) real-time communications, making them unreliable in emergency situations, SpaceX said in a docket 23-135 filing posted Monday. The filing was a response to numerous…
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questions the agency asked SpaceX about its proposed supplemental coverage from space service (see 2409100042). It said its design and operational strategies for orbital debris haven't changed since its previously submitted orbital debris mitigation plan. Moreover, SpaceX said it will ensure its operations won't hurt those of crewed space stations because it will avoid ongoing, nominal operations between altitudes of 385 km and 430 km. SpaceX said it can comply with the agency's OOBE limits only by suppressing its satellites' in-band transit power "and by extension the coverage, throughput, and reliability of supplemental coverage for American people." It said the limits "'will also needlessly delay deployment of realtime emergency communications -- including 911 calling" and necessitate deployment of more capacity to make up for the throughput and coverage limits. The OOBE limits are "nearly ten times more restrictive than necessary for operations in the PCS G Block," SpaceX said, noting it has deployed more than 190 D2D satellites.