December 31, 2024

BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554

Re: SpaceX Gen 2 Semi-Annual and Annual Reports

Dear Ms. Dortch:

Pursuant to its voluntary commitments and reflected in paragraphs 135y, bb, ff, and gg of
the authorization order issued on December 1, 2022, 1 Space Exploration Holdings, LLC provides
the attached end-of-year reports.

If you have any questions, please do not hesitate to direct them to me.

Sincerely,

/s/ David Goldman

David Goldman
Vice President, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Email: [email protected]

Attachments

cc: Merissa Velez

1
See Space Exploration Holdings, LLC, 37 FCC Rcd. 14882, ¶¶ 135y, bb, ff, gg (2022).
 SPACEX SEMI-ANNUALCONSTELLATION STATUS REPORT
June 1, 2023 – November 30, 2024

SpaceX appreciates this opportunity to update the Commission and the public about the
reliability and safety of its second-generation satellite constellation. As this report details, SpaceX
uses extremely conservative assumptions that minimize risk and exceed industry standards and
approaches by a massive margin. In an earlier report, SpaceX detailed how its maneuver threshold
is a minimum of a full order of magnitude more sensitive than the industry standard and how, to
minimize non-maneuverable debris, SpaceX satellites are screened at low altitude shortly after
deployment to ensure functionality. SpaceX also takes an extremely conservative approach when it
chooses to de-orbit satellites and ensures all satellites are fully demisable, exceeding industry
standards and causing no calculable risk to life on the ground. SpaceX’s tightly integrated approach
allows it to quickly identify ways in which it can improve the service, the performance, and the
reliability of its satellites. SpaceX therefore published a blog earlier this year explaining to the public
how it has a bias towards de-orbiting and replacing satellites whenever doing so will improve service
for consumers on the ground and/or enhance the sustainability of space.

SpaceX’s conservative approach requires a significant investment in sustained engineering,

sustainability and performance. Not only must SpaceX invest in satellites that are more capable and
perform more maneuvers that carry considerable cost to SpaceX, but unlike operators with less
emphasis on sustainability, SpaceX proactively deorbits satellites before large issues develop based
on detailed engineering analysis of the likelihood of critical system failures. SpaceX takes this costly
approach out of an abundance of caution to best preserve and protect low Earth orbit.

SpaceX volunteered to report on the health of its system because transparency is critical to
sustainable space operations. But SpaceX cannot maintain long-term space sustainability
unilaterally and without non-U.S. firms participating; no operator, and indeed no country, can do so.
SpaceX therefore pleads once again for other operators—including those that have chosen to license
their satellites outside the U.S. and claim not to be bound by U.S. rules yet want to offer services
here—to provide similar public disclosures about the performance of their satellites. Unfortunately,
very few operators have taken on this same commitment to space sustainability as SpaceX, with
several even claiming that they do not want to disclose their true performance to investors. Yet
even a small system can cause a big risk when operated irresponsibly or without transparency.

The United States can set a strong example by applying its conditions consistently and
requiring transparent operations for all satellite operators. To that end, the Commission should swiftly
ensure that all operators report on the health of their constellations. Doing otherwise could mislead the
public about the relative risk of different systems and is already skewing policy discussions. Only
with the Commission working with all operators equally can we truly maintain space sustainability for
future operations and human space flight.

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RESPONSES TO COMMISSION REQUESTS

1. “Number of conjunction events identified for Starlink satellites during the reporting period,
and the number of events that resulted in an action (maneuver or coordination with another
operator), as well as any difficulties encountered in connection with the collision avoidance
process and any measures taken to address those difficulties.”

Events/Maneuvers—SpaceX uses a significantly more conservative maneuver threshold than the

industry standard. Specifically, during this reporting period, SpaceX satellites maneuvered when the
probability of collision was 1e-6 (1 in 1,000,000 chance of collision), as opposed to the industry
standard of 1e-4 (1 in 10,000 chance of collision). Using very conservative thresholds, along with even
more conservative triggers, SpaceX satellites performed 50,666 propulsive maneuvers over the
reporting period, averaging approximately 35 maneuvers per satellite, per year. SpaceX urges the
Commission to apply its conditions more consistently across all operators so that the public can better
understand industry averages and standard practices.

Less than ten times over this period other operators performed maneuvers to avoid SpaceX satellites.
These maneuvers occurred after coordination with SpaceX.

Other Issues (i.e., “difficulties encountered in the collision avoidance process and the steps taken to
resolve those difficulties”):

Launch Collision Avoidance Gap— A gap in time currently exists between when required launch
collision avoidance screening ends and when satellites are cataloged and screened for conjunctions by
the 19th Space Defense Squadron. This gap can range from one day to several weeks depending on
the number of satellites deployed and the timing of when they are deployed relative to each other.
SpaceX satellites mitigate the launch collision avoidance gap in two ways.

First, SpaceX mitigates collision risk during the launch collision avoidance gap by injecting its
satellites into very low (around 320 km average altitude), sparsely populated orbits relative to all
other operational spacecraft. Second, SpaceX mitigates collision risk during the launch collision
avoidance gap by pre-arranging a set of temporary catalog identification numbers associated with
each satellite. SpaceX then uploads satellite owner/operator ephemerides on Space-Track.org as
close to the deployment time as is possible, given the fact that screening cycles occur every eight
hours and it typically takes several hours to download satellite states and covariance information
after deployment.

Unfortunately, many satellite owner/operators do not pre-arrange the use of the temporary catalog
identification numbers, nor do they screen ephemerides as quickly as is practical post-deployment,
creating unnecessary and avoidable risk for other satellite owner/operators. The practice of early
screening of ephemerides is especially important for missions injecting into existing operational shells
of other systems. All satellite owner/operators should work to generate and screen ephemerides and
covariance beginning as quickly as possible after deployment.

Operator Ephemeris and Covariance Screening and Operator Contact Information on Space-
Track.org—Only a subset of spacecraft on Space-Track.org share their propagated ephemeris and
covariance data such that the 19th Space Defense Squadron can screen them for conjunctions.
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Furthermore, spacecraft operators inconsistently provide and share contact information on Space-
Track.org. Providing accurate propagated ephemerides and realistic covariance significantly
improves collision avoidance screening, provides predictions that include maneuvers, and
improves overall space situational awareness for everyone. SpaceX encourages all spacecraft owners
both to provide contact information on Space-Track.org and to have their ephemerides screened. In
circumstances where SpaceX satellites experience high risk conjunctions with satellites without
owner/operator contact information on Space-Track.org, SpaceX makes every effort to obtain contact
information through other means. But if SpaceX cannot contact the operator of the secondary object,
SpaceX assumes maneuver responsibility and its satellites maneuver to lower the risk.

2. “Satellites that, for purposes of disposal, were removed from operation or screened from
further deployment at any time following initial deployment, and identifying whether this
occurred less than five years after the satellite began regular operations or were available for
use as an on-orbit replacement satellite.”

Can the satellite

Removed <5 years
Satellites that still maneuver for
after beginning
started Deorbit collision
operation?
avoidance?
STARLINK-5662 Yes Yes
STARLINK-5784 Yes Yes
STARLINK-5847 Yes Yes
STARLINK-5962 Yes Yes
STARLINK-6078 Yes Yes
STARLINK-6102 Yes Yes
STARLINK-6103 Yes Yes
STARLINK-6123 Yes Yes
STARLINK-6300 Yes Yes
STARLINK-30115 Yes Yes
STARLINK-30183 Yes Yes
STARLINK-30458 Yes Yes
STARLINK-30419 Yes Yes
STARLINK-30420 Yes Yes

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3. “Satellites that re-entered the atmosphere.”

Re-entered <5
Satellite Date of Reentry years after
Number beginning
operation?

STARLINK-31525 6/1/2024 Yes

STARLINK-31915 6/4/2024 Yes
STARLINK-31194 6/6/2024 Yes
STARLINK-31469 6/13/2024 Yes
STARLINK-30051 6/17/2024 Yes
STARLINK-5904 6/23/2024 Yes
STARLINK-5110 6/26/2024 Yes
STARLINK-32119 7/8/2024 Yes
STARLINK-32116 7/10/2024 Yes
STARLINK-11195 7/12/2024 Yes
STARLINK-11211 7/12/2024 Yes
STARLINK-11212 7/12/2024 Yes
STARLINK-11215 7/12/2024 Yes
STARLINK-11216 7/12/2024 Yes
STARLINK-11217 7/12/2024 Yes
STARLINK-11218 7/12/2024 Yes
STARLINK-11219 7/12/2024 Yes
STARLINK-11220 7/12/2024 Yes
STARLINK-11221 7/12/2024 Yes
STARLINK-11222 7/12/2024 Yes
STARLINK-31743 7/12/2024 Yes
STARLINK-31831 7/12/2024 Yes
STARLINK-31832 7/12/2024 Yes
STARLINK-31839 7/12/2024 Yes
STARLINK-31847 7/12/2024 Yes
STARLINK-32110 7/12/2024 Yes
STARLINK-32146 7/12/2024 Yes
STARLINK-32157 7/12/2024 Yes
STARLINK-32111 7/13/2024 Yes
STARLINK-32115 7/13/2024 Yes
STARLINK-32117 7/14/2024 Yes

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STARLINK-11214 7/16/2024 Yes
STARLINK-11202 7/20/2024 Yes
STARLINK-30097 7/23/2024 Yes
STARLINK-30060 7/24/2024 Yes
STARLINK-30037 7/25/2024 Yes
STARLINK-30057 7/25/2024 Yes
STARLINK-30063 7/25/2024 Yes
STARLINK-30065 7/25/2024 Yes
STARLINK-30050 7/27/2024 Yes
STARLINK-30055 7/27/2024 Yes
STARLINK-30491 8/5/2024 Yes
STARLINK-30046 8/8/2024 Yes
STARLINK-31301 8/10/2024 Yes
STARLINK-31482 8/10/2024 Yes
STARLINK-31672 8/13/2024 Yes
STARLINK-31944 8/15/2024 Yes
STARLINK-30064 8/16/2024 Yes
STARLINK-30417 8/19/2024 Yes
STARLINK-30040 8/23/2024 Yes
STARLINK-31103 8/27/2024 Yes
STARLINK-30047 8/30/2024 Yes
STARLINK-31154 8/30/2024 Yes
STARLINK-31302 8/30/2024 Yes
STARLINK-31105 9/1/2024 Yes
STARLINK-30970 9/9/2024 Yes
STARLINK-30087 9/10/2024 Yes
STARLINK-11278 9/12/2024 Yes
STARLINK-30202 9/18/2024 Yes
STARLINK-31894 9/19/2024 Yes
STARLINK-5380 9/19/2024 Yes
STARLINK-5354 9/22/2024 Yes
STARLINK-31752 9/25/2024 Yes
STARLINK-32187 9/25/2024 Yes
STARLINK-32286 10/6/2024 Yes
STARLINK-31682 10/11/2024 Yes
STARLINK-31429 10/28/2024 Yes
STARLINK-31375 11/3/2024 Yes
STARLINK-30974 11/7/2024 Yes
STARLINK-31703 11/7/2024 Yes

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 STARLINK-30786 11/21/2024 Yes
STARLINK-31118 11/28/2024 Yes
STARLINK-5662 11/28/2024 Yes

4. “Satellites for which there was a disposal failure, i.e., a satellite that loses the capability to
maneuver effectively after being raised from its injection, including a discussion of any
assessed cause of the failure and remedial actions. For each such satellite, SpaceX shall
report an estimated orbital lifetime for the satellite following the failure, and for the Gen2
Starlink constellation the cumulative number of failed satellite object years.”

Satellite Number Cause Remedial Action

Sensitive components have

Suspected power
STARLINK-32368 been identified and removed
failure
from future designs

DAS Decay Time

Perigee Apogee Inclination DAS Area-to-
Satellite Number From 2024-12-01
(km) (km) (deg) Mass Ratio
(years)
STARLINK-32368 388 406 53.0 0.075 0.047

Total Object Years 0.047

Note: STARLINK-32368 reentered on 2024-12-19.

5. “Identification of any collision avoidance system outages or unavailability, either on a

system-wide basis or for individual satellites. An ‘outage’ would include any individual
satellite anomaly that results in a satellite not achieving targeted risk mitigation via
maneuver.”

SpaceX’s onboard collision avoidance system operated nominally during this reporting period and
experienced no prolonged system-wide outages. However, there were several brief outages of Space-
Track.org CDM downloads including 3 instances of Space-Track API failures on separate dates
ranging from 9 to 24 hours in duration and 1 instance of a SpaceX ground service failure resulting in
a 17-hour outage. However, during these short outages, SpaceX satellites were able to minimize
collision probabilities by acting on the best available CDMs from additional sources such as LeoLabs.

During this reporting period, SpaceX identified 100 “outage” events for individual satellites that did
not meet the targeted risk mitigation via maneuver.

6
In 93 events, the CDM arrived with insufficient time to maneuver. For non-maneuvering, radar-only
debris or payloads, this included 47 cases of generally poorly tracked secondary objects with
significant state estimate changes, 25 cases during severe geomagnetic storms (such as that on October
11, 2024) in which drag rapidly evolved over short time frames, and 3 cases shortly following the
launch of payloads into orbits overlapping the Starlink shells. For maneuvering payloads or those with
owner/operator ephemerides, this included 7 cases with noncooperative (radar-only) payloads that
maneuvered just prior to the events, and 11 cases involving third-party operator ephemerides with
poor predictions that did not reflect risk earlier when leading up to the conjunction.

The remaining 7 events precipitated from several types of degraded hardware related issues, which
prevented satellites from fully reducing collision probabilities.

As explained above, an individual satellite may also be unable to achieve its targeted risk mitigation
via maneuver for reasons outside of its control, including CDM latency and space weather. Because
few other operators are required to provide similar information as SpaceX, it is unclear how these
cases compare to industry standards or the relative performance of other systems with respect to late-
arriving CDMs and space weather.

SpaceX committed to ensuring space is safe, sustainable and accessible and continues to aggressively
monitor, assess, adapt and improve its collision avoidance system.
6. “SpaceX must communicate and collaborate with NASA to enable safe launch windows to
support safety of both SpaceX and NASA assets and missions and to preserve long-term
sustainable space-based communications services. SpaceX must report on the progress of its
communications and collaboration efforts to the Commission in its regular reports specified
in condition y.”

SpaceX and NASA meet to discuss space sustainability issues on a regular cadence. Both NASA
and SpaceX mutually work to enable safe launch windows and to preserve long-term sustainable
space-based communications services. SpaceX and NASA exchange information to coordinate
Starlink launch windows and share information to ensure SpaceX satellites transit safely through
International Space Station altitudes. SpaceX also routinely shares launch trajectories and on-orbit
satellite ephemerides and covariance data with NASA to ensure SpaceX and NASA assets and
missions continue to coexist safely. SpaceX values its strong partnership with NASA and will
continue to work closely with NASA to keep space safe and sustainable.

7
 SPACEX GEN2 ANNUAL REPORT
December 1, 2023 – November 30, 2024
Pursuant to paragraphs 135ff and gg of the authorization for its second-generation (“Gen2”)
non-geostationary orbit (“NGSO”) satellite system issued on December 1, 2022, SpaceX provides the
following annual report on its efforts to (1) mitigate the potential impact of its Gen2 satellites on
optical ground-based astronomy and (2) work with the scientific community to collect observational
data on the effects of satellite reentry.
1. “SpaceX must coordinate with NSF to achieve a mutually acceptable agreement to mitigate
the impact of its satellites on optical ground-based astronomy. SpaceX must submit an
annual report to the Commission, by January 1st each year covering the preceding year
containing the following information: (1) whether it has reached a coordination agreement
with NSF addressing optical astronomy; and (2) any steps SpaceX has taken to reduce the
impact of its satellites on optical astronomy, including but not limited to darkening,
deflecting light away from the Earth, attitude maneuvering, and provision of orbital
information to astronomers for scheduling observations around satellites’ locations.”
SpaceX provides the following annual report on its efforts to mitigate the potential impact of
its Gen2 satellites on optical ground-based astronomy. As previously reported, 2 SpaceX has reached
a coordination agreement with the National Science Foundation (“NSF”) addressing optical
astronomy and continues to work closely with NSF on astronomy matters.
Driven by SpaceX's commitment to keep space safe and sustainable, improve user service, and
mitigate impact on optical astronomy, SpaceX has begun operating more than 300 satellites below
inhabited space stations. SpaceX's coordination with NSF documented analysis to determine that
operating satellites at lower altitudes reduces impact on optical astronomy. Analysis shows nearly a
60% reduction in Vera Rubin Observatory images containing an illuminated satellite, when operating
equivalent constellations at 350 km vs. 550 km. SpaceX’s analysis also demonstrates that peak
brightness from nadir surfaces is only marginally increased when operating at 350 km, due to a higher
eclipse fraction and angular rate.
As previously reported, SpaceX has invested significant time and resources, in cooperation
with the astronomy community, to identify the main sources of satellite reflectivity and to develop
strategies and technologies that can reduce the potential for NGSO satellites to affect optical
astronomy. SpaceX has publicly documented many of these steps and incorporates them here. 3
Over the last year, SpaceX has continued to refine its brightness mitigation innovations to
further reduce the effect of its second-generation satellites on optical astronomy. Among other

2
See Letter from David Goldman to Marlene H. Dortch, ICFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-
20210818-00105 (Jan. 17, 2023).
3
Letter from David Goldman to Marlene H. Dortch, ICFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-
20210818-00105 (Dec. 30, 2022); SpaceX, “Brightness Mitigation Best Practices for Satellite Operators,”
https://api.starlink.com/public-files/BrightnessMitigationBestPracticesSatelliteOperators.pdf (last visited Dec. 30,
2024).
1
efforts, SpaceX has:
 Continued collection of publicly corroborated systematic brightness measurements, the
results of which SpaceX has used to further reduce edge cases;
 Participated actively in astronomy conferences to share satellite brightness mitigations
SpaceX has developed and to promote brightness mitigation best practices;
 Published high-fidelity satellite trajectory and maneuver data, which operators of
highly sensitive ground telescopes may use to best schedule observations at times least
likely to be affected by Gen2 satellites; and
 Developed and made freely available software to calculate satellite brightness for any
astronomers or other satellite manufacturers to use.
SpaceX will continue to work with the assistance of the astronomy community, including
NSF, to develop steps to further reduce the effect of satellites on optical astronomy. SpaceX has
greatly benefited from its discussions to date and expects that they will continue to bear fruit. SpaceX
will also publish very accurate state predictions for its Gen2 satellites.
But SpaceX reiterates that it cannot address these issues alone and without non-U.S. firms
participating; no operator, and indeed no country, can do so. SpaceX therefore pleads once again for
the Commission to apply its rules consistently and for other operators—including those that have
chosen to license their satellites outside the U.S. and claim not to be bound by U.S. rules yet want to
offer services here—to join in the effort to mitigate the impact of their satellites on optical astronomy.
Only with consistent application of conditions and all operators working together and cooperating
with the astronomy community can we hope to preserve opportunities for optical astronomy even as
satellites make productive use of valuable spectrum and orbital resources.
2. “SpaceX must follow its commitment to work with the scientific community to explore
methods to collect observational data on formation of alumina from satellite reentry, to
implement reasonable methods that are discovered to the extent practicable, and to report
findings from these measurements taken to the Commission, as part of its annual report
specified in condition gg.”
Over the last year, SpaceX continued to work with members of the scientific community to
explore methods to collect observational data on reentering satellites. Because uncontrolled satellite
reentries make observing and taking measurements extremely impractical, SpaceX has been
investigating operational approaches to improve the predictability of reentering satellites including
the possibility of targeting reentry for deorbiting Starlink satellites to a small fraction of their orbit.
Ideally these efforts will improve the ability to measure reentries.