Radiation Hazard Analysis

Phased Array Fixed Earth Station

Introduction

This analysis updates the radiation hazard analysis previously provided in connection with ICFS
File No. SES-LIC-20230228-00228 to account for SpaceX Services Inc.’s (“SpaceX” or “SpaceX
Services”) current request to operate these user terminals at higher maximum EIRP. Two user
terminal versions are currently authorized under that application: one larger form factor (Version
1) and one smaller form factor (Version 2). This analysis provides updated analyses for both
configurations.

The calculations performed in this analysis comply with the methods described in FCC Office of
Engineering and Technology Bulletin, Number 65 (Edition 97-01) (“Bulletin 65”). This analysis
demonstrates that SpaceX Services UTs will not result in exposure levels exceeding the applicable
radiation hazard limits. As detailed below, SpaceX requests authority to operate at combinations
of duty cycles and EIRPs that result in exposure levels within FCC limits.

Bulletin 65 and Section 1.1310 of the Commission’s rules specify two separate tiers of exposure
limits: one for Occupational/Controlled Exposures and one for General Population/Uncontrolled
Exposures. Limits for Occupational/Controlled Exposures apply in situations where persons are
exposed as a consequence of their employment and are fully aware of and can control their
exposure. These limits also apply in situations where a person is transient through a ___location where
such limits would otherwise apply provided the person is made aware of the potential for exposure.
The limits for General Population/Uncontrolled Exposure apply in situations in which the general
public may be exposed, or in which persons that are exposed as a consequence of their employment
may not be fully aware of the potential for exposure or cannot exercise control over their exposure.

SpaceX Services will deploy two types of each UT version, one for General Population
/Uncontrolled Environments and one for Occupational/Controlled Environments, especially for
enterprise customers. These two types differ only in the software that determines their maximum
duty cycle. As a result, this analysis discusses the Maximum Permissible Exposure (“MPE”) limit
for both the General Population/Uncontrolled exposures and the Occupational/Controlled
exposures, which for the Ku-band frequencies used by these UTs is a power density equal to 1
mW/cm2 averaged over a thirty-minute period and 5 mW/cm2 averaged over a six-minute period,
respectively.1

Because this application requests authority to deploy two different versions of the UT hardware,
SpaceX Services presents four radiation hazard analyses below, one for each of the two versions
of the UT hardware for uncontrolled settings and one for each of the two versions of the UT
hardware in occupational/controlled settings.

As described in the definitional section below, this report analyzes the maximum power density
levels in the vicinity of a UT antenna in three regions: (1) the far field, (2) the near field, and (3)

1
See 47 C.F.R. § 1.1310(e).

1
near the main reflector surface. These radiation regions were analyzed using the definitions and
formulas in Bulletin 65 for aperture antennas. Note that the SpaceX Services UTs are flat phased
array antennas, such that the other region normally included in analyses for parabolic dishes (i.e.,
between the main reflector and the feed) is not applicable in this case.2 The results of this analysis
are summarized in Tables 1 and 2 for the first version of the UT and Tables 3 and 4 for the second
version of the UT, which identifies the potential exposure under worst-case operating conditions.

The Commission’s website indicates that Bulletin 65 is currently under review to reflect updated
guidance to applicants.3 However, in the interest of timely review of this application and in an
abundance of caution, the results of an analysis reflecting the Updated IEEE Standard are
summarized in Tables 1 and 3 (for the General Population/Uncontrolled version) and Tables 2
and 4 (for the Occupational/Controlled version), similarly identifying the potential exposure
under worst-case operating conditions. However, SpaceX notes that this standard is excessively
conservative for SpaceX’s phased array antennas and therefore results in more limited broadband
service for American consumers.

UT Description

The UTs are flat phased array antennas capable of steering beams to track NGSO satellites
passing within their field of view. At the phased array’s equivalent of an “antenna flange,” the
highest transmit power is 5.01W and 5.15W for UT Versions 1 and 2, respectively.

The UTs transmit bursts of information at designated times that are assigned to the UT by the
network. The duty cycle of the uplink transmissions is controlled by the network and
independently monitored by the software controlling the UT; this ensures that the transmit duty
cycle of a UT cannot exceed a specified level under any circumstances.

Explanation of the Analysis

The “Calculated Values” in Tables 1-4 are calculated using the formulas from Bulletin 65 for a
system with continuous (100% transmit duty cycle) transmission. But SpaceX Services UTs
transmit only short bursts of data periodically as instructed by the network and are neither
designed for nor capable of continuous transmission. Therefore, to compute the effective radiated
power density of a SpaceX Services UT, the UT’s maximum possible transmitter duty cycle has
been adjusted using the Bulletin 65 methodology. Accordingly, the calculated figures reflect the
total potential for human exposure based on the length of time that the UTs transmit energy during
the relevant period for consideration. Tables 1-4 reflect operations at the maximum requested
EIRP levels. SpaceX may also operate at lower EIRPs and higher duty cycles, as appropriate,
while ensuring the exposure levels remain within FCC limits. Figures 1-4 illustrate the
2
Bulletin 65 also calls for consideration of the transition region between near field and far field. However, the
power density in the transition region will be less than the maximum power density in the near field and more
than the minimum power density in the far field for the purpose of evaluating potential exposure. Accordingly,
if the analysis demonstrates compliance for both the near field and far field, it necessarily demonstrates
compliance for the transition region.
3
See Federal Communications Commission, “OET – Bulletins On-line,” https://www.fcc.gov/general/oet-
bulletins-line (visited February 27, 2023).

2
operational envelope of each UT — specifically the relationship between EIRP and maximum
duty cycle — to illustrate SpaceX’s compliance with FCC exposure limtis at lower EIRP levels.

Results of Analysis

This analysis demonstrates that the SpaceX Services UTs are not a radiation hazard because the
UTs do not exceed (1) the MPE limit of 1 mW/cm2 averaged over a thirty-minute period when
used in General Population/Uncontrolled environments, and (2) the MPE limit of 5 mW/cm2
averaged over a six-minute period when used in Occupational/Controlled environments.

Conclusion

This radiation hazard analysis demonstrates that SpaceX Services UTs will not result in exposure
levels exceeding the applicable MPE limits.

3
Definitions

1) Far Field Region

The far field region extends outward from the antenna surface, beginning at a distance
!.#$ !
of & meters where the D is the diameter of the antenna. The maximum power density is
calculated using the equation recommended in Bulletin 65.

2) Near Field Region

The near field region is a volume co-incident with the direction of the main beam extending
$!
outward from the antenna surface the length of the near field '& meters.

3) Transition Region

The transition region is located between the near field region and the far field region. This
region has a power density that decreases with increasing distance. Therefore, the power
density in the transition region will be less than the maximum power density in the near field
and more than the maximum power density in the far field for the purpose of evaluating
potential exposure.

4) Region Near the Antenna Surface

The power density near the antenna surface can be estimated as equal to four times the power
divided by the area of the main reflector surface (phased array illumination is uniform).

4
 TABLE 1: RADIATION FROM SPACEX PHASED ARRAY UT VERSION 1
(GENERAL POPULATION / UNCONTROLLED)4

Input Parameters
Antenna Dimensions, D1, D2 0.57, 0.36 m

Frequency, f 14.25 GHz

Max Power into antenna, Pmax 5.01 W
Max EIRP, EIRPmax 22908.7 W

Max EIRP, 10 log(EIRPmax) 43.6 dBW

Aperture efficiency, η 78.5%

Maximum Transmit Duty Cycle at Max EIRP, DTx5 8.0%

Calculated Values
"
Wavelength, 𝜆 = #
0.0211 m

Area of Reflector, A = D1 D2 0.2052 m2

'()*
Max Antenna Gain, 𝐺$%& = +!
4567.1

Max Antenna Gain, 10 log(Gmax) 36.6 dBi

-"!
Length of Near Field, 𝑅,# = 3.86 m
(+

-"!
Beginning of Far Field, 𝑅## = 0.6 9.26 m
+

Maximum Power Density Calculations

./01#$%
Power Density in Far Field, 𝑆## = 𝐷𝑇𝑥 !
()0&& 0.17 mW/cm2

(1#$%
Power Density in Near Field, 𝑆,# = 𝐷𝑇𝑥 '*
0.99 mW/cm2

Power Density Off-axis Near Field

7'& 0.01 mW/cm2
(20dB below peak), 𝑆,#,3##4%&56 =
899

(1#$%
Power Density at Antenna Surface, 𝑆:;# = 𝐷𝑇𝑥 *
0.78 mW/cm2

4
Calculated Values and Power Density Calculations may vary due to rounding.
5
As averaged over 30 minutes per FCC OET Bulletin 65 Supplement C.

5
 TABLE 2: RADIATION FROM SPACEX PHASED ARRAY UT VERSION 1
(OCCUPATIONAL / CONTROLLED) 6

Input Parameters
Antenna Dimensions, D1, D2 0.57, 0.36 m

Frequency, f 14.25 GHz

Max Power into antenna, Pmax 5.01 W
Max EIRP, EIRPmax 22908.7 W
Max EIRP, 10 log(EIRPmax) 43.6 dBW

Aperture efficiency, η 78.5%

Maximum Transmit Duty Cycle at Max EIRP, DTx7 40%

Calculated Values
"
Wavelength, 𝜆 = 0.0211 m
#

Area of Reflector, A = D1 D2 0.2052 m2

'()*
Max Antenna Gain, 𝐺$%& = +!
4567.1

Max Antenna Gain, 10 log(Gmax) 36.6 dBi

-"!
Length of Near Field, 𝑅,# = 3.86 m
(+

-"!
Beginning of Far Field, 𝑅## = 0.6 9.26 m
+

Maximum Power Density Calculations

./01#$%
Power Density in Far Field, 𝑆## = 𝐷𝑇𝑥 ! 0.85 mW/cm2
()0&&

(1#$%
Power Density in Near Field, 𝑆,# = 𝐷𝑇𝑥 4.98 mW/cm2
'*

Power Density Off-axis Near Field

7'& 0.05 mW/cm2
(20dB below peak), 𝑆,#,3##4%&56 = 899

(1#$%
Power Density at Antenna Surface, 𝑆:;# = 𝐷𝑇𝑥 *
3.91 mW/cm2

6
Calculated Values and Power Density Calculations may vary due to rounding.
7
As averaged over 6 minutes per FCC OET Bulletin 65 Supplement C.

6
 TABLE 3: RADIATION FROM SPACEX PHASED ARRAY UT VERSION 2
(GENERAL POPULATION / UNCONTROLLED)8

Input Parameters
Antenna Dimensions, D1, D2 0.29, 0.25 m

Frequency, f 14.25 GHz

Max Power into antenna, Pmax 5.15 W
Max EIRP, EIRPmax 8317.6 W

Max EIRP, 10 log(EIRPmax) 39.2 dBW

Aperture efficiency, η 78.5%

Maximum Transmit Duty Cycle at Max EIRP, DTx9 2.7%

Calculated Values
"
Wavelength, 𝜆 = 0.0211 m
#

Area of Reflector, A = D1 D2 0.0725 m2

'()*
Max Antenna Gain, 𝐺$%& = +!
1613.6

Max Antenna Gain, 10 log(Gmax) 32.1 dB

-"!
Length of Near Field, 𝑅,# = 1.00 m
(+

-"!
Beginning of Far Field, 𝑅## = 0.6 2.40 m
+

Maximum Power Density Calculations

./01#$%
Power Density in Far Field, 𝑆## = 𝐷𝑇𝑥 !
()0&& 0.32 mW/cm2

(1#$%
Power Density in Near Field, 𝑆,# = 𝐷𝑇𝑥 '*
0.99 mW/cm2

Power Density Off-axis Near Field

7 0.01 mW/cm2
(20dB below peak), 𝑆,#,3##4%&56 = '&
899

(1#$%
Power Density at Antenna Surface, 𝑆:;# = 𝐷𝑇𝑥 0.77 mW/cm2
*

8
Calculated Values and Power Density Calculations may vary due to rounding.
9
As averaged over 30 minutes per FCC OET Bulletin 65 Supplement C.

7
 TABLE 4: RADIATION FROM SPACEX PHASED ARRAY UT VERSION 2
(OCCUPATIONAL / CONTROLLED)10

Input Parameters
Antenna Dimensions, D1, D2 0.29, 0.25 m

Frequency, f 14.25 GHz

Max Power into antenna, Pmax 5.15 W
Max EIRP, EIRPmax 8317.6 W
Max EIRP, 10 log(EIRPmax) 39.2 dBW

Aperture efficiency, η 78.5%

Maximum Transmit Duty Cycle at Max EIRP, DTx11 13.8%

Calculated Values
"
Wavelength, 𝜆 = #
0.0211 m

Area of Reflector, A = D1 D2 0.0725 m2

'()*
Max Antenna Gain, 𝐺$%& = 1613.6
+!

Max Antenna Gain, 10 log(Gmax) 32.1 dBi

-"!
Length of Near Field, 𝑅,# = 1.00 m
(+

-"!
Beginning of Far Field, 𝑅## = 0.6 2.40 m
+

Maximum Power Density Calculations

./01#$%
Power Density in Far Field, 𝑆## = 𝐷𝑇𝑥 ! 1.59 mW/cm2
()0&&

(1#$%
Power Density in Near Field, 𝑆,# = 𝐷𝑇𝑥 '*
4.99 mW/cm2

Power Density Off-axis Near Field

7'& 0.05 mW/cm2
(20dB below peak), 𝑆,#,3##4%&56 = 899
(1#$%
Power Density at Antenna Surface, 𝑆:;# = 𝐷𝑇𝑥 *
3.92 mW/cm2

10
Calculated Values and Power Density Calculations may vary due to rounding.
11
As averaged over 6 minutes per FCC OET Bulletin 65 Supplement C.