Marlene H.

Dortch
April 20, 2021
Page 2 of 2

Commissioners demanding unilateral conditions placed on SpaceX’s operations. 1 Ironically, the

conditions demanded by OneWeb would make it more difficult to successfully coordinate
operations going forward, demonstrating more of a concern with limiting competitors than with a
genuine concern for space safety.

These tactics are just the latest escalation of a disturbing trend by non-U.S. operators to
influence U.S. regulators and policy makers with respect to space safety. Similarly, Viasat has
been making misrepresentations about space safety and demanding unilateral restrictions on
competitors in scores of Commission filings and public statements. At the same time, both Viasat
and OneWeb have argued forcefully that they should be exempt from Commission rules for orbital
debris mitigation due to their status as non-U.S. operators. The Commission can help curb this
hypocritical behavior by acting swiftly on SpaceX’s petition to extend its orbital debris rules to all
operators, including those like OneWeb and Viasat, that choose to license their systems overseas
but seek to provide service in the U.S. market. This unified regime will help align all operators’
interests in a sustainable space environment.

Finally, SpaceX discussed the importance of transparent operations. SpaceX is proud to

be the first operator to provide both its ephemerides and covariance data to the 18th Space Control
Squadron for all operators to access. Maintaining a sustainable space environment is a shared
responsibility and it is incumbent on all operators to take their responsibility seriously.

Sincerely,

/s/ David Goldman

David Goldman
Director of Satellite Policy

SPACE EXPLORATION TECHNOLOGIES CORP.

1155 F Street, NW
Suite 475
Washington, DC 20004
Tel: 202-649-2691
Email: [email protected]

cc: FCC Participants

Attachments

1
See Letter from Brian D. Weimer to Marlene H. Dortch, IBFS File No. SAT-MOD-20200417-00037 (Apr. 14,
2021).
 ATTACHMENT A

FCC Participants
Karl Kensinger
Jameyanne Fuller
Joe Hill
Marissa Valez
Jennifer Gilsenan
Troy Tanner
Tom Sullivan

SpaceX
Tim Hughes
Patricia Cooper
Mat Dunn
David Goldstein
Erik Babcock
Jeff Tooley
Kevin Wu
David Goldman

OneWeb

Brian Weimer
John Guiney
Ruth Pritchard-Kelly
Eric Graham
Attachment B
 FACT SHEET
Operator to Operator Physical Coordination: SpaceX-OneWeb

Recent Successful Technical Coordination: No Close Call and Inaccurate Information Provided to Media
• OneWeb’s head lobbyist recently made demonstrably inaccurate statements to the media about recent
coordinations of physical operations. Specifically, Mr. McLaughin of OneWeb told the Wall Street
Journal that SpaceX switched off its AI-powered, autonomous collision avoidance system and “they
couldn’t do anything to avoid a collision.” Rather, SpaceX and OneWeb were working together in good
faith at the technical level. As part of these discussions, OneWeb itself requested that SpaceX turn off
the system temporarily to allow their maneuver, as agreed by the parties, per the chronology, below.
• The recent technical coordination with OneWeb was not an exceptional event and the Starlink team has
successfully conducted similar coordinations with other satellite owner/operators.
• Technical data indicates that this event was neither a “close call” and not “urgent” nor as reported in the
press, presumably based on information provided by OneWeb.
• According to the valid conjunction data messages (“CDM”), the probability of conjunction was between
1 in 10,000 (1e-4) and 1 in 100,000 (1e-5) during the time of the interaction, which is near the floor of
the maneuver threshold of 1 in 100,000 (1e-5).
• All operator-to-operator interactions between SpaceX and OneWeb to date have involved open,
constructive technical discussions.

Chronology
1. OneWeb contacted SpaceX by email on 4/1/2021 at 18:26 UTC (see timeline below with corresponding
numbers) regarding a notice from the United States Space Force's 18th Space Control Squadron (“18
SPCS”), SpaceX responded within minutes and communicated to OneWeb that Starlink-1546 was/is
maneuverable.
2. OneWeb asked SpaceX via email on 4/2/2021 12:20 UTC for more detail, and SpaceX responded minutes
later to explain that.
• the maneuver threshold for Starlink satellites is 1e-5 and that maneuvers occur approximately 12
hours before the predicted closest approach of the satellites.
• Starlink-1546 was maneuverable and its autonomous collision avoidance system was functioning
nominally.
• if a maneuver was needed, typically a single in-track burn would be conducted to reduce collision
probability.
3. SpaceX and OneWeb conducted a call on 4/2/2021 at 17:30 UTC.
• The 18 SPCS had provided no new CDMs at this point, but LeoLabs CDMs showed low probability
of collision (“Pc”).
• OneWeb stated that OneWeb-0178 was not maneuvering at that time.
• OneWeb acknowledged that the covariance (i.e., accuracy) in its propagated ephemerides (i.e.,
predicted location of satellites) are biased low and this bias is a known issue.
• Given the acknowledged issues with OneWeb covariance data, SpaceX de-weighted/discounted the
validity of SpaceX vs OneWeb CDMs (yellow triangles in plot below).
• SpaceX volunteered to perform a manual maneuver, but both parties agreed to wait for the next
CDM.

1
4. SpaceX and OneWeb had a second call on 4/2/2021 at 19:15 UTC.
• 18 SPCS had provided no new CDMs at this point.
• SpaceX reiterated its recommendation to wait for another CDM from 18 SPCS before planning a
maneuver because SpaceX systems indicated this was the least risky approach.
• OneWeb satellites need more time to coordinate and plan their maneuvers than Starlink satellites
require, so OneWeb did not want to wait and chose instead to maneuver OneWeb-0178.
• Because OneWeb decided to plan a maneuver, it asked SpaceX to turn off Starlink-1546’s
autonomous conjunction avoidance system. SpaceX obliged this request and confirmed to OneWeb
that the system had been turned off.
5. OneWeb sent an email to SpaceX on 4/2/2021 at 22:50 UTC with the maneuver plan and the ephemerides
they had screened by 18 SPCS.
• After the maneuver was planned, 18 SPCS provided its latest CDM that showed Pc below standard
maneuver thresholds.
• All subsequent CDMs show continued lowering Pc. In other words, the probability of collision was
already below any threshold that required a maneuver and kept dropping.
6. While all CDM Pc values remained below the maneuver threshold, OneWeb-0178 maneuvered on 4/3/2021
at 11:27 UTC.
• 18 SPCS reported actual miss distance as 1,120 m.
• LeoLabs reported actual miss distance as 1,072 m.
• Both 18 SPCS and LeoLabs reported final Pc below 1e-20—one in one hundred million million
million—this was not a close call or a near miss.

Background
• The 18 SPCS sends satellite operators alerts whenever satellites have conjunctions that have (i) a time of
closest approach within 72 hours, (ii) a probability of collision greater than 1/10,000 (1e-4), and (iii) a
miss distance less than 1 km.
• If the notice is for two maneuverable satellites, the satellites’ operators contact each other to coordinate
potential collision avoidance maneuvers, i.e., maneuvers that reduce collision probability
• The first satellite operations coordination between SpaceX and OneWeb was over a year ago on March
12, 2020.
o 18 SPCS provided notice of a conjunction between ONEWEB-0052 and Starlink-1057, and the
parties held coordination discussions.
o Based on these discussions, Starlink-1057 did an autonomous conjunction avoidance maneuver
for this case.
• Between March 2020 and prior to the early April 2021 conjunction with OneWeb, Starlink satellites
have conducted many autonomous maneuvers to reduce collision probabilities, with no issues.