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Here is the actual ex parte filing: https://cdn.arstechnica.net/wp-content/uploads/2021/08/Amazon-Ex-Parte-on-S.pdf https://cdn.arstechnica.net/wp-content/uploa

by koboll 5y ago

Here is the actual ex parte filing: https://cdn.arstechnica.net/wp-content/uploads/2021/08/Amazon-Ex-Parte-on-S.pdf https://cdn.arstechnica.net/wp-content/uploads/2021/08/Amazo... It is quite short and basically alleges SpaceX failed to fulfill various requirements when filing its amendment. Mainly, it alleges SpaceX submitted two different configuration options and the Commission's rules require them to settle on a single configuration option to submit. Are those legitimate allegations? I have no idea. I'm not an expert on FCC amendment rules, and I doubt many here are either. But it seems kind of misleading to call that "because it can't compete" when the filing says something completely different.

ineedasername 5y ago
But it seems kind of misleading to call that "because it can't compete" when the filing says something completely different. Well, it's not like Amazon is going to say "we're 3 years behind SpaceX so we need you to slow them down" It's also not a good look for Amazon when it has has significantly more contact with the FCC over SpaceX than in providing its own details in response to FCC questions But this is just SpaceX's side of things, so I'll take it with a grain of salt. Also Amazon may fully expect the FCC to reject their request and simply wants that precedent set for when it needs/wants to submit a similarly flexible plan for their own deployment.
xt00 5y ago
https://fcc.report/IBFS/SAT-AMD-20210818-00105/12943361 https://fcc.report/IBFS/SAT-AMD-20210818-00105/12943361 "In Configuration 1—SpaceX’s preferred scenario—the amendment proposed herein would revise the pending application in three main respects to fully leverage these new capabilities: 1. SpaceX will more evenly spread capacity by latitude by targeting multiple inclinations, ensuring better, more consistent global coverage even as it continues to operate at lower, more sustainable altitudes than most other NGSO systems. 2.SpaceX will nearly double the number of satellites deployed in a sun-synchronous orbit optimized for key throughput demand times and service to Polar Regions, resulting in additional capacity for those chronically underserved areas such as Alaska. 3.The revised orbital planes will enable “single plane” launch campaigns, not requiring long dwell times in a low parking orbit waiting for orbital precession to spread satellites into other planes. These satellites can launch, be checked out at low altitude, and can all quickly go to their on-station positions. Configuration 2 utilizes a smaller number of satellites per plane than Configuration 1, yet also spreads capacity more evenly by latitude for more consistent coverage across the globe. Neither configuration requests any additional spectrum or results in a significant increase in the potential for interference to any other spectrum user, including other NGSO licensees and current applicants. Although SpaceX proposes to rearrange the orbital parameters of its Gen2 System, it will slightly reduce the number of satellites in the constellation. Moreover, SpaceX will continue to leverage the inherent advantages of operating at lower altitudes than most NGSO constellations. Not only will atmospheric drag at these altitudes ensure that any debris quickly disintegrates in the atmosphere and pose no further danger to space operations or life on the ground, but operation at these altitudes is also consistent with a key recommendation from the astronomical community to minimize any effect on astronomical observations. "
YooLi 5y ago
Why does Amazon feel it’s their job to check compliance to the FCCs rules?
- shaklee3 5y ago
  Because they share the same spectrum, orbital slots, sky, etc.

by koboll 5y ago

ineedasername 5y ago

But it seems kind of misleading to call that "because it can't compete" when the filing says something completely different. Well, it's not like Amazon is going to say "we're 3 years behind SpaceX so we need you to slow them down" It's also not a good look for Amazon when it has has significantly more contact with the FCC over SpaceX than in providing its own details in response to FCC questions But this is just SpaceX's side of things, so I'll take it with a grain of salt. Also Amazon may fully expect the FCC to reject their request and simply wants that precedent set for when it needs/wants to submit a similarly flexible plan for their own deployment.

xt00 5y ago

https://fcc.report/IBFS/SAT-AMD-20210818-00105/12943361 https://fcc.report/IBFS/SAT-AMD-20210818-00105/12943361 "In Configuration 1—SpaceX’s preferred scenario—the amendment proposed herein would revise the pending application in three main respects to fully leverage these new capabilities: 1. SpaceX will more evenly spread capacity by latitude by targeting multiple inclinations, ensuring better, more consistent global coverage even as it continues to operate at lower, more sustainable altitudes than most other NGSO systems. 2.SpaceX will nearly double the number of satellites deployed in a sun-synchronous orbit optimized for key throughput demand times and service to Polar Regions, resulting in additional capacity for those chronically underserved areas such as Alaska. 3.The revised orbital planes will enable “single plane” launch campaigns, not requiring long dwell times in a low parking orbit waiting for orbital precession to spread satellites into other planes. These satellites can launch, be checked out at low altitude, and can all quickly go to their on-station positions. Configuration 2 utilizes a smaller number of satellites per plane than Configuration 1, yet also spreads capacity more evenly by latitude for more consistent coverage across the globe. Neither configuration requests any additional spectrum or results in a significant increase in the potential for interference to any other spectrum user, including other NGSO licensees and current applicants. Although SpaceX proposes to rearrange the orbital parameters of its Gen2 System, it will slightly reduce the number of satellites in the constellation. Moreover, SpaceX will continue to leverage the inherent advantages of operating at lower altitudes than most NGSO constellations. Not only will atmospheric drag at these altitudes ensure that any debris quickly disintegrates in the atmosphere and pose no further danger to space operations or life on the ground, but operation at these altitudes is also consistent with a key recommendation from the astronomical community to minimize any effect on astronomical observations. "

YooLi 5y ago

Why does Amazon feel it’s their job to check compliance to the FCCs rules?

shaklee3 5y ago
Because they share the same spectrum, orbital slots, sky, etc.