The FCC is inexplicably inconsistent about conditions it places on satellite constellations, SpaceX representatives told the offices of the five agency commissioners, said a filing Friday in docket 18-313. SpaceX said that while the agency has put 100 object-year caps -- that's the number of years each failed satellite remains in orbit, added up across all the satellites -- on some constellations, it has not done so with Amazon's proposed 3,232-satelite Kuiper constellation. Nor has it required that Kuiper report cumulative object-years any failures represent, though it has required such reporting of some other constellations, SpaceX said. "Now that a greater number of operators are beginning to deploy their systems in earnest, the Commission must ensure that the Bureau applies Commission-level precedent consistently and avoids providing special treatment," SpaceX said.

Viasat's argument that assessing a satellite constellation's regulatory complexity should consider factors beyond altitude (see 2405170032) ignores that there is "a direct, physics-based relationship" between altitude and regulatory complexity issues, such as spectrum efficiency and complexity of orbital debris, SpaceX representatives told FCC Space Bureau staffers, according to a filing Friday in docket 24-85. A large system at a lower orbit can present much less complexity than a smaller, higher one, it said. It said the FCC repeatedly rejected constellation size as a good proxy for system complexity and the work burden on staff. "Using a proceeding to determine regulatory fees to reverse this long-standing policy, while rejecting an altitude-based proxy that directly aligns with system complexity, would be arbitrary and capricious," it said.

Comments are due June 27, replies July 12, as the FCC Space Bureau seeks a refresh of the record on proposed orbital debris mitigation rules, said a notice for Tuesday's Federal Register. The bureau said it was seeking a refresh on such issues as whether to measure collision risks in the aggregate for a non-geostationary orbit constellation or on a per satellite basis and what factors would be relevant in conducting an aggregate risk analysis. It also seeks input on using a 100 object-years metric -- the number of years each failed satellite remains in orbit, added across all the satellites -- for assessing the risk of derelict satellites in orbit from a constellation. The rules came from a Further NPRM that was adopted in 2020 alongside the FCC's orbital debris order (see 2004230040). Comments are due in docket 22-271.

AST SpaceMobile's BlueWalker 3 satellite has become the subject of a regulatory letter-writing campaign, with numerous filings in docket 23-65. Monday saw more than 20 posted in the FCC docket complaining about satellites impacting astronomy. Many of the letters singled out BlueWalker 3 as "so bright that it could actually damage sensitive cameras in research telescopes at its peak brightness" and said that masses of such satellites in orbit will limit astronomy. Multiple letters (for example, here) urge that the agency consider brightness in any satellite approval process. None of the letters, purportedly filed by individuals, indicates if an organization is spearheading the letter-writing work, and many contain identical or near-identical wording. AST didn't comment Monday.

Viasat's Inmarsat is trying to make a bigger push into maritime connectivity as it unveiled its NexusWave service Monday. The connectivity offering ties together Inmarsat's Global Express low earth orbit Ka-band connectivity with coastal LTE service and, starting in 2025, ViaSat-3 geostationary orbit Ka-band service. Inmarsat Maritime President Ben Palmer said while maritime has often had to rely "on multiple, disjointed solutions ... NexusWave fulfills all of those demands."

SpaceX's supplemental coverage from space service (SCS) testing in the 1990-1995 MHz band is causing harmful interference to Omnispace's mobile satellite service (MSS) operations, according to Omnispace. In an FCC docket 23-65 filing posted Monday, Omnispace said co-channel emissions from SpaceX satellites are interfering with its MSS satellite receiver. It said SpaceX is operating outside its authorized parameters. "Enforcement is warranted," Omnispace said. It said medium earth orbit satellite and terrestrial antenna monitoring chronicled the interference, and showed it was due to SpaceX operations and not T-Mobile's terrestrial G-block base stations with downlink operations in the 1990-1995 MHz band. Omnispace said the interference was due to at most a pair of SpaceX test satellites, given the separation of the satellites in orbit. It said SpaceX's planned direct-to-device service at scale would cause aggregate interference hundreds of times greater, making the band unusable by other MSS operators over large swaths of the planet. Omnispace said that while SpaceX is authorized to conduct SCS testing at altitudes of 525-535 km, its observations show SpaceX doing such testing at 350-360 km. It said Space Force data also shows SpaceX operating at lower-than-authorized altitudes, which "cannot be dismissed as a mere oversight or a response to dynamic on orbit conditions." Omnispace has expressed concerns previously to the FCC about likely interference from SpaceX's SCS plans (see 2305190057). In a letter to Omnispace posted Monday in the docket, SpaceX said it was "extremely concerned" about public statements that it has empirical evidence of SpaceX interference. It asked that the evidence be put into the record. SpaceX also requested that Omnispace put into the public record evidence of service disruptions.

The FCC Space Bureau has again approved satellite plans while imposing some conditions sought by SpaceX. In an order in Monday's Daily Digest, the bureau signed off on the Tomorrow Companies' plans for a quartet of non-geostationary orbit weather satellites (see 2212020001). The approval included conditions akin to what the agency imposed on SpaceX's second-generation constellation. For example, if the cumulative projected lifetime of Tomorrow's failed satellites exceeds 100 years, it can't deploy additional satellites without the commission approving a license modification that updates Tomorrow's orbital debris mitigation plan with ways it will address the failure rate. The agency also conditioned Tomorrow's approval on requiring coordination with NASA, including operator-to-operator coordination of physical operations. The bureau said it was deferring action on the remaining 14 satellites in the company's request. SpaceX has urged the agency to put similar conditions on numerous operators as were imposed on its second-generation constellation, and the agency earlier this month imposed some SpaceX-sought conditions on Planet Labs satellites (see 2405130045).

Arguments that the relative risk of non-geostationary orbit satellites depends solely on their altitude ignore factors like constellation size and satellite mass, Viasat said Friday in docket 24-85. Assessing NGSO regulatory fees based on altitude risk alone "would be the epitome of arbitrariness," Viasat said. An NGSO system's size is "an imprecise proxy for staff work [but] it is at least a rational one," and levying regulatory fees in part based on NGSO constellation size "would ensure that the fee burden more closely aligns with the systems that occupy staff time the most," it said. Meanwhile, Intelsat representatives, meeting with FCC Space Bureau and Office of Managing Director staff, said the proposed 40% hike in regulatory fees that will pay for the creation of the Space Bureau is too big a bite to swallow at once. It urged a five-year phase-in.

Kepler, a backer of SpaceX's call for a rulemaking to open the 1.6./2.4 GHz "Big LEO" band to more operators (see 2405130035), met with FCC Space Bureau staff to push for such a rulemaking, according to a filing Friday. The company said a rulemaking would be a venue for it and other interested parties to provide technical analyses showing the feasibility of sharing in the band.

Turion Space is hoping for a February launch for its non-geostationary orbit Droid.002 satellite, it said in an FCC Space Bureau license application posted Friday. The satellite, plus Turion's Droid.001 launched last June, will collect imaging for space situational awareness services, it said.