The new requests consist of 20 filings requesting to deploy 1,500 satellites each in 20 different orbital bands around the earth. These filings are laying down the gauntlet for other planned satellite providers like OneWeb that has plans for 1,910 satellites, Kuiper (Jeff Bezos) with plans for 3,326 satellites and Samsung with plans for 4,600 satellites.
The Starlink announcements are likely aimed at stirring up regulators at the ITU, which is meeting at the end of this month to discuss spectrum regulations. The FCC has taken the lead in developing satellite regulations. Earlier this year the FCC established a rule where an operator must deploy satellites on a timely basis to keep the exclusive right of the spectrum needed to communicate with the satellites. Under the current FCC rules, a given deployment must be 50% deployed within six years and completely deployed within nine years. In September, Spacelink revised its launch plans with the FCC in a way that meets the new FCC guidelines, as follows:
|Satellites||Altitude (Km)||50% Completion||100% Completion|
|Phase 1||1,584||550||March 2024||March 2027|
|Phase 2||2,493||336||Nov 2024||Nov 2027|
This is an incredibly aggressive schedule and would require the company to launch 5,902 satellites by November 24, 2024, or 120 satellites per month beginning in November 2019. To date, the company has launched 62 satellites. The company would then need to step launches up to 166 per month to complete the second half on time.
I’m guessing that Starlink is already starting to play the regulatory game. For example, if they can’t meet the launch dates over the US in that time frame, then some of the constellations might not work in the US. If the company eventually launches all of the satellites it has announced, then every satellite would not need to serve customers everywhere. If the ITU adopts a timeline similar to the US, then it’s likely that other countries won’t award spectrum to every one of the Starlink constellations. Starlink will be happy if each country gives it enough spectrum to be effective there. Starlink’s strategy might be to flood the sky with so many satellites that they can provide service anywhere as long as at least a few of their constellations are awarded spectrum in each country. There are likely to be countries like North Korea, and perhaps China that won’t allow any connections with satellite constellations that bypass their web firewalls.
Starlink faces an additional challenge with many of the planned launches. Any satellite with an orbit at less than 340 kilometers (211 miles) is considered as very low earth orbit (VLEO) since there is still enough earth atmosphere at that altitude to cause drag that eventually degrades a satellite orbit. Anything deployed at VLEO heights will have a shorter than normal life. The company has not explained how it plans to maintain satellites at the VLEO altitudes.
At this early stage of satellite deployment, there is no way to know if Starlink is at all serious about wanting to launch 42,000 satellites. This may just be a strategy to get more favorable regulatory rules. If Starlink is serious about this, you can expect other providers to speed up plans to avoid being locked out of orbital paths. We’re about to see an interesting space race.