Image of a Starlink terminal on a residence. Photo: SpaceX

SpaceX submitted a request to the FCC to modify the second generation, Gen2, of its Starlink satellite system with changes that SpaceX said will allow the constellation to deliver gigabit-speed broadband. 

SpaceX submitted the filing to the FCC on Oct. 11, and it was made public on Tuesday. The operator wants to make changes to the orbital configuration and operational parameters, and requests modifications for its Gen2 frequency authorization. 

These modifications “will enable the Gen2 system to deliver gigabit-speed, truly low-latency broadband and ubiquitous mobile connectivity to all Americans and the billions of people globally who still lack access to adequate broadband,” Jameson Dempsey, SpaceX director of Satellite Policy said in the filing. 

For comparison, Starlink’s current statement on service speeds is that users typically experience download speeds between 25 and 220 Mbps, and a majority of users experience speeds over 100 Mbps.

In 2022, the FCC partially approved SpaceX to deploy a Gen2 Starlink constellation of up to 7,500 satellites for fixed satellite services (FSS) in the Ku- and Ka-bands, then later authorized Gen2 operations using additional frequencies in the E- and V-bands. 

SpaceX reported that since then, it has deployed more than 3,000 satellites in the Gen2 system and the full Starlink constellation serves more than four million people. 

Request for More Flexible Spectrum

SpaceX is requesting more flexible spectrum for the constellation. According to the filing, SpaceX seeks authority to use its authorized frequency ranges in the Ku-, Ka-, V-, and E-band for both fixed-satellite service (FSS) and mobile-satellite service (MSS) in frequency ranges that share allocations for both FSS and MSS. 

More flexible spectrum use will serve the public interest by accelerating the realization of 6G connectivity, SpaceX said. 

“As 6G interweaves mobile and fixed, as well as terrestrial and satellite, networks, next-generation satellite operators will require not just reliable access to these frequencies, but more flexible access too. Indeed, in the near future, an end user will be able to seamlessly switch from a home fixed satellite broadband connection to a terrestrial cell tower to supplemental coverage from space and then to an ESIM-enabled Wi-Fi connection on an airplane or vessel over the course of a single day,” the filing says. 

SpaceX also asks to use these authorized Ku-, Ka-, V-, and E-band frequencies for user links. This would “better enable SpaceX to deploy equipment for consumer, enterprise, and government use cases to meet individual capacity needs,” the filing says. 

EPFD Waiver and Lower Altitude

SpaceX is also requesting a waiver for equivalent power flux-density (EPFD) limits. EPFD limits were the subject of a lot of discussion around the WRC-23 spectrum conference from both Geostationary (GEO) and Non-Geostationary Orbit (NGSO) operators. SpaceX has petitioned the FCC to update the limits. 

“SpaceX requests to waive the current EPFD limits for downlink operations within the United States, reflecting commission policy finding that those limits are outdated, overly restrictive, and harm consumers, competition, and satellite innovation,” the filing says. 

SpaceX asserted that its proposed operations will protect GSO FSS and broadcasting satellite service (BSS) networks in downlink from unacceptable interference. 

In addition, SpaceX asked to lower the altitude of its orbital shells (see graphic), arguing it will improve post-mission disposal and reduce latency for customers. 

Lowering the altitude could also have implications for future Starlink launches using Starship. According to the filing, reducing the nominal inclination to leverage Starship for Starlink launches more quickly. Starship launches from Boca Chica, Texas, “may initially require lower-inclination launches than SpaceX’s workhorse Falcon launch vehicle,” the filing says. 

SpaceX’s request to modify the altitude and inclination of Gen2 Starlink satellites. Screenshot via FCC filing.