The section on orbital tolerances: 79. Collision Risk at Specific Operational Altitudes. Viasat and Kuiper assert that the 468 satellites SpaceX proposes to op

The section on orbital tolerances: 79. Collision Risk at Specific Operational Altitudes. Viasat and Kuiper assert that the 468 satellites SpaceX proposes to operate in the 604 km and 614 km shells will not comply with the Commission’s individual satellite collision risk metric of 0.001.305 Viasat also expresses concern with satellites planned for operations at 360 km.306 Since we do not authorize satellites planned for operations at these altitudes in this grant, we do not reach these issues. 80. Orbital Tolerances. The satellites authorized in this grant are planned for operations in orbital shells centered at altitudes from 525 km to 535 km. SpaceX has requested orbital tolerances of +70 km and -50 km, i.e., the satellites in any orbital shell can be maintained for regular operations anywhere within an altitude range of 70 kilometers above or 50 kilometers below the center altitude. The Gen2 Starlink satellites in the authorized shells would, if this request is granted, be authorized for regular operations at altitudes ranging from as low as 475 km to as high as 605 km.307 This represents a substantially larger range of altitudes than for the Gen1 Starlink satellites. SpaceX states that this orbital tolerance will allow the satellites in Gen2 Starlink to retain their operational life in periods of high drag and maintain low passive decay times in the event the satellite becomes non-maneuverable.308 81. If we were to authorize SpaceX’s operations with the orbital tolerance requested, Gen2 Starlink satellite operations would be permitted at altitudes within the altitudes at which Kuiper’s constellation will operate, beginning at altitudes around 580 km and above. Kuiper requests that we require SpaceX to limit the orbital tolerances of its satellites to keep its operations below 580 km.309 Kuiper does not object to orbital overlap with smaller systems and agrees with SpaceX that nothing in the Commission’s rules limits which orbits an operator may choose, but Kuiper emphasizes the risks posed by the overlap of two systems operating at the scale of Kuiper’s and SpaceX’s proposed operations and requests that the Commission require SpaceX to operate all Gen2 Starlink satellites at or below 580 km 82. The record does not reflect with any specificity a need for Gen2 Starlink satellite operations at altitudes above 580 km, as opposed to the +45 to +55 km tolerance that can be achieved if operations are maintained below 580 km. We also note that one of the reasons for larger orbital tolerances that SpaceX identifies—effects of solar radiation on the orbits of spacecraft—is less pronounced for the particular orbital shells authorized by this grant than for lower altitudes. We will follow the approach of the SpaceX Third Modification Order,311 and require SpaceX to restrict its Gen2 Starlink operations to below 580 km. We condition this authorization accordingly. However, this action is without prejudice to any determination we may make with respect to requirements such as orbital separation or coordination for large constellations as is currently under consideration in a separate rule making proceeding.