Ensuring Innovation andGrowth Opportunities in theNew Space Age – doc copy

This paper focuses on the pressing issues surrounding the race to populate the portion of
space closest to Earth known as Low Earth Orbit (LEO). Unless the situation is suitably
managed at the market access stage, the way LEO is being populated today poses a threat
to innovation, growth opportunities, efficient spectrum use, national interests, space safety,
and the environment.
These threats exist because a few large constellations consisting of many thousands of LEO
satellites, so called “mega constellations,” risk creating many harmful effects:

Consuming an undue amount of spectrum and orbits in contravention of the
International Telecommunication Union (ITU) Constitution, specifically Article 44,
paragraph 2, which recognizes that radio frequencies and orbits are limited natural
resources and must be used “rationally, efficiently, and economically;”

Generating undue interference that reduces the reliability and capacity of other satellite
systems, and constrains their ability to innovate and offer new services, including those
offering direct to home (DTH) television, Broadcast Satellite Services (BSS), and
broadband connectivity;

Precluding equitable access to spectrum and orbits (both NGSO & GSO);

Unduly raising the risks and costs associated with access to and use of space (regardless
of orbit), including collisions and the creation of lethal orbital debris;

Limiting consumer choice, adversely affecting national space industries, and threatening
national security interests;

Creating numerous environmental and other sustainability risks that may limit the
deployment of additional NGSO systems:
o Damaging the Earth’s atmosphere and effecting climate change through radiative
forcing and depletion of the ozone layer, thus increasing the risk of cancer and
other negative health effects, because thousands of large LEO satellites reenter
the atmosphere on a regular basis at the end of their short lives;
o Impairing critical optical and radio astronomical research by disrupting the visible
night sky and causing radio interference;
o Creating light pollution, with the resulting negative impacts on the health and
quality of life of humans and on plants and animals; and
o Impairing the functioning of critical asteroid detection and defense capabilities.
The development of a stable global space economy requires that access to space be safely
and reliably available to more than a few LEO systems from select nations. Indeed, the
existence of “have nots” in the space economy could be a destabilizing force that we can
and must avoid. Moreover, ensuring innovation and growth opportunities requires that we
maintain a known interference environment that allows the certain deployment and
operation of GSO and NGSO satellites by all nations in the limited resources that the entire
world must share.
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As leading experts and a leading legal institution emphasize, (i) it is imperative that
preventative action be taken now at the national level because we just won’t reach
international consensus in the short term on a new framework for regulating large LEO
constellations,
1 and (ii) it is critical to address the potential national harms at the market
access stage, because that is “one of the rare decisions, if not the only one, taken by [a
nation] which conditions the provision of [satellite] services” in its territory.2
The 2022 Plenipotentiary Conference of the ITU (ITU PP-22) also recognized the need to
address as a matter of urgency concerns around the sustainable use of orbits and spectrum
created by the “continued and expanded launch and operation of a large number of nongeostationary satellites in outer space.”3 ITU PP-22 called on member administrations to
“take all necessary actions to avoid unacceptable interference to GSO and other non-GSO
systems, as well as to other radio services, of other administrations and to ensure the
efficient use of radio-frequency spectrum and associated orbits; to this effect, the necessary
regulatory frameworks need to be developed for the operation of non-GSO systems.”
National regulators should consider these issues, discussed in further detail below, in relation
to any requests they receive to license or grant market access to NGSO satellite systems.
II. Interference into GSO networks and threats to equitable and safe access to space
Reliable access to both sufficient spectrum and other orbital resources is a key driver in the
ability of satellite services to meet evolving commercial, civic and military needs. Moreover,
a growing recognition exists that these resources are limited and must be carefully managed
to ensure that all needs for satellite-based services can be met—including new applications
for remote sensing/earth observation; science; defense; positioning, navigation and timing
(PNT); and communications, alike.
At this early stage of the New Space Age, we are seeing a few actors in LEO staking claims to
vast amounts of orbital resources in a manner that risks hindering innovation and growth
opportunities in industry. These very real risks include:

Creating impermissible interference into GSO networks that interrupts broadband
and direct-to-home video (DTH) operations and reduces network capacity;

1
R. Buchs, “Policy Options to Address Collision Risk from Space Debris,” Lausanne: EPFL International Risk
Governance Center (2021), at ii (“Given that the prospect of reaching consensus in the short term is very
low, governments are advised to take unilateral but coordinated action by improving their national
regulations.”).
2
Le Conseil d’État invalidation of Starlink market access, conclusions of rapporteur, Case No. 455321 (Apr.
5, 2022) (France).
3
International Telecommunication Union, Final Acts of the Plenipotentiary Conference (Bucharest, 2022),
Committee 5, Resolution 4, adding resolution titled “Sustainability of the radio-frequency spectrum and
associated satellite orbit resources used by space services” (Final Acts, p. 398-399),
https://www.itu.int/dms_ties/itu-s/md/22/pp/c/S22-PP-C-0202!!PDF-E.pdf.
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• Hindering equitable access by other NGSO systems to shared NGSO frequency
  bands;
• Hindering safe and reliable access to the lower portions of LEO that are needed so
  others can provide spectrum-based services; and
• Consuming more than an equitable share of the aggregate amount of interference
  that all NGSO systems (considered together) may generate into GSO networks.
  By taking actions to manage these risks now, national regulators can ensure that their
  policies keep pace with changes and innovations in the space sector, and that opportunities
  continue to exist for growth in the provision of satellite-based services in their countries.
  The critical issues discussed below should be addressed at a national level prior to granting a
  license or market access to an NGSO system. Doing so would mitigate the risk of
  interference between an NGSO system and GSO networks and ensure that limited spectrum
  and orbital resources are shared equitably among NGSO systems.
  A. Impermissible interference into GSO networks

1. NGSO system angular separation is needed to protect GSO networks from
   interference
   The movements of NGSO satellites across the sky create opportunities for time varying
   interference into GSO networks. Unless an NGSO operator employs appropriate mitigation
   measures, in-line interference events with GSO networks will repeatedly degrade and
   disrupt services to end users of GSO networks.
   Today’s GSO satellites are extremely efficient in how they use spectrum to provide
   innovative services to smaller user terminals than ever possible before. Taking advantage of
   advancements in technology, GSO satellites now can provide more than 1 Tbit/s of total
   capacity each, with far greater levels of throughput coming in the next few years.
   GSO networks achieve this unprecedented increase in capacity due in part to increased
   spectral efficiency which is facilitated by employing satellite receivers with low noise
   temperatures and high antenna gains (high G/T). Today, even a single NGSO system has the
   potential to cause interference into GSO networks. Multiple NGSO systems operating
   simultaneously on the same frequencies pose an even greater aggregate interference risk
   to those GSO networks.
   Unless an NGSO system’s communication links are angularly separated from the GSO arc by
   a sufficient degree, they could easily degrade service levels and cause capacity losses to GSO
   networks, including those that serve or plan to serve a given country.
   Angular separation is a relatively simple operational technique whereby the NGSO satellites
   avoid operating within a suitable angular separation zone around the GSO arc. If using one
   specific NGSO satellite to serve a given location would not maintain sufficient angular
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   separation, then a different satellite would be used, and the first NGSO satellite would be
   used to serve a different location where it would be able to maintain the required angular
   separation. This concept is depicted below in Figure 1.
   Figure 1: NGSO system employing GSO avoidance angle
   Angular separation imposes virtually no constraint on NGSO system capacity because large
   NGSO systems always have multiple options for assigning different satellites to serve
   locations on the Earth. Further, they regularly hand-off traffic from one NGSO satellite to
   another as the satellites move rapidly across the sky. Angular separation is routinely used
   by NGSO systems in ITU coordination agreements to protect GSO networks.
   Certain LEO constellations would not comply with various ITU Radio Regulation
   requirements designed to protect GSO networks from interference generated by NGSO
   systems. A key operational requirement for complying with these non-interference
   requirements is for the NGSO system to greatly reduce the amount of unwanted energy it
   generates toward GSO networks, including by maintaining a suitable avoidance angle with
   respect to the GSO orbital arc. Certain LEO operators have disavowed any responsibility to
   maintain any such avoidance angle, much less a suitable one. National regulators therefore
   should consider appropriate NGSO system conditions, like the requirement to meet a
   specific angular separation, to mitigate the risk of interference to GSO networks in the first
   place.4

4 See, e.g., In re Space Exploration Holdings, LLC, Request for Orbital Deployment and Operating Authority
for the SpaceX Gen2 NGSO Satellite System, FCC 22-91 (rel. Dec. 1, 2022), at ¶16 (“SpaceX must operate
consistent with the technical specifications provided to the Commission as part of its application […]. The
relevant technical information includes antenna beam patterns; GSO avoidance angle, physical
characteristics; frequencies used for satellite communications, including outside the United States; and
other technical information.”) (emphasis added), https://www.fcc.gov/document/fcc-partially-grantsspacex-gen2-broadband-satellite-application.
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The effectiveness of GSO arc avoidance as a potential way to mitigate interference from
NGSO systems into GSO networks depends entirely on the avoidance angle that is specified.
The sufficiency of that angle can be evaluated only (i) based on information about the
radiofrequency design and equivalent power flux density performance of the relevant NGSO
system, and (ii) by taking into account the actual characteristics of the GSO networks that
would be affected (such as satellite receiver noise temperature and antenna gain, and sizes
and characteristics of user terminals).
These facts underscore the need to define up-front appropriate parameters that are shown
through mathematical calculations to be reasonably likely to mitigate the potential for
interference from NGSO systems into GSO network operations—e.g., by specifying a precise
and appropriate GSO arc avoidance angle on an ex-ante basis.
For these reasons, a suitable demonstration of the existence of adequate measures to avoid
undue interference from an NGSO system should be provided before granting any
authorization to serve a given country. In these cases, a national regulator should, at a
minimum: (i) calculate the minimum GSO arc avoidance angle that would ensure that the
NGSO system protects from interference those GSO networks serving its country; (ii) allow
interested parties to evaluate the efficacy of the proposed value; and (iii) require the NGSO
system to maintain a suitable GSO arc avoidance angle as a condition of any authorization
that ultimately may be granted.
To assist in that analysis, national regulators should require all NGSO applicants to provide
the following information:
● The number of satellite beams used for transmissions on the same frequency in the
same or overlapping areas at any given time; and
● How the NGSO system avoids interference to GSO networks created by earth station
and satellite antenna sidelobes, and earth station antenna backlobes, particularly
when phased array antennas are employed.
This information is relevant to assessing an NGSO system’s potential interference into GSO
networks, the potential for spectrum sharing with other NGSO systems discussed below,
and, more broadly, the impact of the NGSO system on the spectrum environment in a
country and the satellite sector.
In sum, a national regulator should require:
● An NGSO system to maintain a suitable GSO arc avoidance angle when serving its
territory;
● An NGSO system not to cause unacceptable interference into GSO networks and not
to claim interference protection from GSO networks;
● An NGSO system to have an operational feature that allows it to immediately
interrupt radio frequency emissions to ensure satisfaction of this non-interference
requirement, and to cease emissions upon notice of unacceptable interference; and
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● That if interference into a GSO network occurs, an NGSO system must cease
operations and not recommence operations until it addresses the cause of such
interference by, among other things, increasing angular separation, reducing power,
and shaping antenna beams differently.
In order to ensure that the basis on which a national regulator grants an NGSO authorization
does not change by virtue of continuing iterations of its NGSO system design, a national
regulator should also: (i) specify that the NGSO operator not modify the radiofrequency
characteristics of its satellite system without prior consent from the national regulator, and
(ii) require that the NGSO operator provide a bi-annual report on iterations of its NGSO
system design to ensure compliance with that condition.

2. Failures to comply with ITU EPFD limits that constrain interference into GSO
   networks
   The potential for disruption to GSO networks by co-frequency NGSO systems is well-known
   and is what led to the development of various ITU Radio Regulations (RR) intended to
   protect GSO networks from interference generated by NGSO systems and define the terms
   under which both GSO and NGSO systems are to coexist.
   These provisions include:
   ● RR No. 22.2, which requires NGSO systems not to cause unacceptable interference
   to, or claim interference protection from, GSO networks;
   ● In certain frequency bands, equivalent power flux density (EPFD) limits that, if
   actually met during operation, fulfill the RR No. 22.2 obligation with respect to an
   NGSO system; and
   ● In other frequency bands, a requirement that NGSO systems coordinate under RR
   No. 9.11A based on ITU network filing date priority.
   As discussed above, a key operational requirement for complying with these noninterference requirements is for the NGSO system to greatly reduce the amount of
   unwanted energy it generates toward GSO networks, including by maintaining a suitable
   avoidance angle with respect to the GSO orbital arc.
   There are two types of EPFD interference limits.

• “Aggregate” EPFD limits constrain the amount of interference that all NGSO systems
  may generate in total, on a cumulative basis. These aggregate limits must be shared
  and apportioned among all NGSO systems using overlapping frequencies.
• “Single-entry” EPFD limits constrain the amount of interference that one NGSO
  system itself may generate with respect to GSO networks. The single-entry limits
  were established based on the assumption that 3.5 NGSO systems would be
  operating at a given time and generating combined EPFD levels consistent with the
  applicable “aggregate” EPFD limits.
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  Both “single-entry” and “aggregate” EPFD limits are specified as a series of different EPFD
  levels that are permitted for time-varying intervals and are reflected in the EPFD curves
  described and depicted in Annex A.
  5
  As further explained in Annex A, one EPFD limit must
  be satisfied 100 percent of the time; other EPFD limits must be satisfied for other, varying
  percentages of time.
  Certain LEO operators propose to operate in a manner that would not comply with these
  limits. Unless prevented at the market access stage, such operations would generate
  excessive interference and could well:
• Degrade service levels and cause capacity losses to broadband GSO networks as well
  as direct-to-home video (DTH) services, and
• Forestall continued technological innovation by GSO networks.
  In addition, such excessive operations would consume the entire EPFD budget that must be
  shared and apportioned among all NGSO systems using overlapping frequencies, making it
  difficult, if not impossible, for other NGSO systems to share the same spectrum.
  As illustrated in Annex A, certain NGSO systems would exceed the “single-entry” EPFD limits
  and, in some cases, the “aggregate” EPFD limits as well. Exceeding the “single-entry” EPFD
  limits at any point on the EPFD curve and at any location on Earth visible from the GSO orbit
  is a violation of the ITU Radio Regulations.6 Exceeding the “aggregate” EPFD limit at any
  point on the curve and at any location on Earth also is a violation.
  The instances described in Annex A in which an NGSO system would violate “single-entry”
  EPFD limits 1%, 10% and even 100% of the time are very concerning. Interference
  generated at those levels could well degrade service levels and cause capacity losses to GSO
  networks and constrain technological innovation. Annex A evaluates one specific
  interference case in Germany; similar analyses conducted for other locations around the
  world yield similar exceedances and violations of ITU limits.
  These violations of EPFD limits can occur because geometry cases (geographic locations of
  GSO earth stations and satellites) within many nations are not tested by the limited
  examination conducted by the ITU, as explained in Annex A.

5
Annex A, Examples of Violations of EPFD↓ Limits (Fuchsstadt, Germany).
6
RR 22.5C provides in relevant part: “The equivalent power flux-density, epfd ↓, at any point on the Earth’s
surface visible from the geostationary-satellite orbit, produced by emissions from all the space stations of
a non-geostationary-satellite system in the fixed-satellite service in the frequency bands listed in Tables
22-1A to 22-1E, including emissions from a reflecting satellite, for all conditions and for all methods of
modulation, shall not exceed the limits given in Tables 22-1A to 22-1E for the given percentages of time.”
(emphasis added; footnote omitted).
ITU-R Recommendation. S.1503-3 similarly explains the necessity of complying with all EPFD limits at all
locations: “The epfd limits in Article 22 are applicable for all GSO [earth station]s and all pointing angles
towards that part of the GSO arc visible from that [earth stations. [] It remains necessary for the non-GSO
operator to meet the epfd limits in Article 22 for all [] geometries including the testing of specific GSO
networks as noted in § A1.3.9.” (emphasis added).
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Violations also can result from NGSO operators’ attempts to ignore the way in which an
NGSO system actually would operate and instead:

• Artificially separate an NGSO system into constituent components, and
• Impermissibly evaluate each of those constituent components (instead of the NGSO
  system as a whole) against the “single entry” EPFD limits.7
  The Director of the ITU’s Radiocommunication Bureau recently released a report which
  explains that the practice of splitting a non-geostationary satellite system into several filed
  systems, “may affect the effectiveness of single-entry epfd limits contained in Article 22 to
  protect geostationary systems or have an impact in the implementation of Resolution 76
  (Rev.WRC-15).”8
  As that report details, this issue was first studied in 2003, and the
  conclusion reached then was: “the only reason for misapplication of these single entry epfd
  limits by artificially splitting or combining non-GSO FSS systems, will be to lower the epfd
  levels and therefore to get a favourable finding status as a result of this regulatory
  examination.”9
  However, the ITU alone cannot effectively check all of the ways an NGSO system operator
  may try to “game” the system in this manner, by contriving EPFD inputs in a way designed to
  “pass” the ITU’s spot checks regarding EPFD without reflecting how the NGSO system
  actually would operate and affect every nation. Notably, that responsibility falls on
  individual administrations and regulators that consider authorizing, or granting market
  access to, NGSO system operations.10
  Moreover, it ultimately falls on the NGSO operator to conduct its operations in full
  compliance with all of the Radio Regulation’s EPFD limits at all locations around the world,
  regardless of any limited evaluation initially conducted by the ITU for a limited set of
  locations and based merely on the data files provided by that operator and without regard
  to the actual operation of the NGSO system.
  It would be practically impossible in the future to directly measure the NGSO-generated
  EPFD levels generated into GSO networks. Among other things, EPFD statistics include a
  percentage-of-time element, such that EPFD levels would need to be measured over and
  against time and then processed to check against the EPFD limits—a process that is

7 One NGSO operator plans to operate various elements of its integrated system under a variety of ITU
filings made on its behalf by at least three administrations.
8 Director, ITU Radiocommunication Bureau, Preliminary Draft Report of the Director to WRC-23 on the
Activities of the Radiocommunication Sector Experience in the Application of the Radio Regulatory
Procedures and Other Related Matters, Addendum 2 to Document 4-3 (September 2023), at 28-29.
Resolution 76 is discussed below. It addresses compliance with limits on the entirety of the aggregate
EPFD↓ created by all NGSO systems of all operators.
9
Id. at 29, quoting 2003 CPM Report, Chapter 3, §3.1 (addressing WRC-03 agenda item 1.19 “to consider
regulatory provisions to avoid misapplication of the non-GSO FSS single-entry limits in Article 22 based on
the results of ITU-R studies carried out in accordance with Resolution 135 (WRC-2000)”).
10 Nevertheless, the U.S. Federal Communications Commission (FCC) has indicated that it did not and will not
conduct any such analysis of an NGSO system, deferring instead to an ITU evaluation processes for the
underlying filings, despite the known shortcomings as discussed both here and in Annex A.
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computationally intensive and time-consuming for the same reasons that any up-front EPFD
analysis is time-consuming. In addition, where multiple NGSO systems operate in the same
band, it is not practical to differentiate between the contributions of each NGSO system
given all the main-beam and sidelobe transmissions of numerous satellites of those multiple
NGSO systems. Multiple NGSO systems already operate in the same frequency bands.
The way in which different NGSO systems contribute to the overall EPFD level received by a
GSO earth station is illustrated by Figure 2, below. From the perspective of the GSO earth
station, EPFD interference is EPFD interference—i.e., the GSO earth station cannot isolate
individual components of that interference or trace those components to their specific
sources.
Figure 2: Aggregate mainlobe and sidelobe interference contributions from multiple NGSO
systems into a GSO earth station
Even when they are applied properly, the existing EPFD limits (developed over 20 years ago)
are under-protective of today’s GSO networks. The US Federal Communication Commission
(FCC) has acknowledged that existing EPFD limits “were not developed with the most
advanced modern GSO networks in mind.”11 Indeed, those limits were designed to protect
decades-old GSO network designs and do not adequately protect either (i) today’s ultrahigh-throughput GSO satellites, or (ii) the sub 1-meter antennas that GSO network (and
NGSO systems alike) use to meet customer demands.
It is essential that NGSO systems satisfy all EPFD limits in each and every nation that they
serve, and that a national regulator evaluate an NGSO system’s EPFD compliance within its
territories before granting market access.

11 Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related
Matters, 32 FCC Rcd 7809, ¶ 35 (2017).
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For these reasons, a national regulator should:

• Conduct its own analyses to ensure that an NGSO system seeking to serve its
  territories can comply with all single-entry EPFD limits within those territories, with
  the national regulator viewing all NGSO system filings under which the NGSO system
  operates as a collective;
• Require that an NGSO system comply with all single-entry EPFD limits across the
  entirety of the system, with the national regulator again viewing all NGSO system
  filings under which the NGSO system operates as a collective;
   In other words, require that an NGSO system operate such that it does not
  exceed any of the EPFD limits established for an individual NGSO system just
  as if it were relying on a single ITU filing for all co-frequency operations;
• Conduct its own analyses of the aggregate EPFD levels from all NGSO systems
  seeking to serve its territories to ensure that the aggregate EPFD levels do not
  exceed any of the EPFD limits; and
• If aggregate interference to a GSO network from signals transmitted by multiple
  NGSO systems is detected, and it is not possible to identify the NGSO system
  generating the interference, require that the NGSO system operators cooperate with
  each other and take the technical measures necessary to eliminate the interference.
  B. Hindering equitable access to shared NGSO frequency bands
  Large NGSO systems with thousands of satellites can consume significant portions of the
  “look angles” toward space and LEO orbits as well, preventing use of the sharing tools that
  have been employed successfully for decades among certain NGSO systems. This threat to
  NGSO spectrum sharing occurs when large LEO constellations “blanket the sky,” causing
  many in-line interference events limiting and sometimes completely blocking other NGSO
  systems from sharing the same spectrum. A large NGSO system would rarely (if ever)
  experience this problem itself because it has a far greater number of satellites than smaller
  NGSO constellations, which provides the large NGSO system with alternative
  communications paths in which the same spectrum remains available for its use. These
  impacts are depicted in Annex B.
  The upshot is that a large NGSO system would have little incentive to avoid in-line
  interference events; large numbers of in-line interference events would harm smaller NGSO
  systems without materially impacting the large NGSO system’s operations. As a result, the
  large NGSO system could hinder other satellite operators, including new entrants, from
  accessing and using shared spectrum and orbital resources in the public interest. One large
  NGSO operator acknowledged these kinds of risks when it objected to a proposal that it
  claimed would allow another NGSO operator to access twice the amount of spectrum
  compared to other Ku/Ka-band NGSO operators: “control of two systems in a band would
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  reduce the incentives to invest in technologies that use spectrum efficiently and increase the
  incentives for obstructionism and gamesmanship in operator-to-operator coordination.”12
  Moreover, this dynamic has the dangerous effect of incentivizing a “race to the bottom” in
  which NGSO systems deploy many more satellites than actually are needed, utilizing large
  numbers of spectrally-inefficient satellites, and rejecting reasonable approaches that
  otherwise would enable spectrum sharing among all NGSO systems – even those operating
  at other altitudes.
  In sum, efforts by some large NGSO operators to “blanket the sky” can have direct and
  harmful consequences for other NGSO systems and operators – and can harm innovation,
  industry growth, and the broader public interest.
  To avoid this result, it is critical to adopt a condition requiring “look angle” splitting,
  whereby NGSO systems serving a country in overlapping frequencies would divide the range
  of satellite azimuths as seen from a location on the Earth whenever the potential for
  NGSO/NGSO interference exists at that location.13 For example, on such occasions one
  system would only operate with satellites to the West of that location while the other
  system would only operate with satellites to the East of that location. As long as each
  system has a satellite available in its assigned West or East direction from that location that
  is not within the minimum avoidance angle of a satellite in the other system in its assigned
  West or East direction from that location, there would be no capacity reduction.
  Notably, the same level of “look angle” splitting would occur regardless of the number of
  satellites in a given NGSO constellation. Each operator would bear the same burden by
  default, in the absence of some other coordinated outcome. This approach would allow
  multiple NGSO systems to access available spectrum resources on an equitable basis.
  Specifically, national regulators should condition licenses for large NGSO constellations to
  ensure they do not hinder equitable access to shared and limited NGSO orbital resources by
  requiring NGSO systems authorized to serve their countries to:
  ● Operate with only 1/n of the look angles in a given country, where n is the number
  of NGSO systems authorized to serve that country in the same frequency band, and

12 Petition to Deny or Defer of Space Exploration Holdings, LLC, U.S. Federal Communications Commission,
IBFS File Nos. SAT-LOI-20170301-00031 and SAT-AMD-20180104-00004, at 13 (Aug. 6, 2018) (emphasis
added).
13 In similar cases, the United States imposes spectrum-splitting constraints on “foreign” NGSO systems that
seek U.S. market access. See, e.g., In re Kinéis, Petition for Declaratory Ruling to Access the U.S. Market
Using a Low-Earth Orbit Satellite System, FCC 21-118 (rel. Dec. 19, 2021) at ¶¶ 2, 12 (French LEO system
granted U.S. market access under the following condition: “Absent a coordination agreement, spectrum
will be divided among licensees and grantees of U.S. market access pursuant to section 25.157 of the
Commission’s rules.”), https://www.fcc.gov/document/fcc-grants-market-access-kineis-low-earth-orbitsatellites-0. The US approach, however, disproportionately disadvantages smaller NGSO systems for the
reasons explained in Annex B.
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● Coordinate in good faith and in advance with other NGSO systems so that all n look
angles may be used to serve that country by those different NGSO systems.
With this approach, NGSO systems would be on an equal footing, regardless of system size,
incentivizing all NGSO systems to coordinate, preserving and promoting new opportunities
for industry growth in the country.
C. Hindering safe and reliable access to shared LEO orbits
A further threat to spectrum sharing exists because orbits in which LEO satellites must
operate in order to use spectrum are limited, and as leading experts recognize14 LEO megaconstellation operators are in a race to populate (with huge numbers of satellites) a wide
swath of the orbits in the 300 km to 700 km range that are important for many strategic
purposes, such as the missions of earth observation, remote sensing15 and PNT16 satellites.
These altitudes are also attractive for other purposes because of their associated passive
decay times for failed satellites (which can deorbit much more quickly than from higher
orbits).17
LEO mega-constellation operators are engaging in a “land grab” of these orbital resources
by planning to operate with unnecessarily wide orbital tolerances, effectively filling up
hundreds of kilometers of orbits and hindering the ability of other LEO systems to operate
safely in nearby orbits. This would impact the ability of other LEO systems to use these
orbits to provide innovative services to the public and distort the existing balance in LEO—
all of which is particularly critical to avoid at this very early stage of the New Space age.
The sheer number of satellites proposed to populate these orbits (over 34,000 from one
operator alone) is problem enough, but the harmful impact is magnified by the overly wide
orbital tolerances within which they propose to operate. One LEO operator proposes to
operate across hundreds of kilometers in LEO—including in large shells that would spread
from 290 km to 430 km and 475 km to 687 km. As depicted below in Figure 3, this result
would occur because it seeks to operate anywhere from 50 km below, to 70 km above, each
of the nominal altitudes for its various orbital shells.18

14 See, e.g., “Elon Musk’s shot at Amazon flares monthslong fight over billionaires’ orbital real estate” (Jan.
27, 2021), https:/www.theverge.com/2021/1/27/22251127/elon-musk-bezos-amazon-billionairessatellites-space.
15 See, e.g., European Space Agency, eduspace, “Earth observation satellites – Introduction”
https://www.esa.int/SPECIALS/Eduspace_EN/SEM7YN6SXIG_0.html.
16 See “What Are LEO Satellites and Why Are They Good for PNT?” https://www.orolia.com/what-are-leosatellites-and-why-are-they-good-for-pnt/.
17 Other current and forthcoming satellite broadband systems operate in different orbits.
18 See U.S. Federal Communications Commission, IBFS File No. SAT-AMD-20210818-00105, at 4 (Aug. 18,
2021). SpaceX plans to operate the first generation of its Starlink satellites with orbital tolerances that
would spread from 510 km to 580 km.
http://www.viasat.com 14
Figure 3: Extent of physical orbits proposed to be consumed by one large LEO system
The net effect would be to hinder other LEO systems from being able to safely and reliably
access approximately 86 percent of the altitudes between 300 km and 700 km, regardless of
frequency band (only 45 km of altitude between 430 km and 475 km might be available to
other NGSO systems).
The large LEO system would have limited incentive to allow other LEO systems to operate in
the orbital ranges depicted in Figure 3. Particularly given that LEO systems already operate
within much narrower orbital tolerances, there is no good reason to allow it to provide
service to a country utilizing overlapping shells of satellites in very wide orbits that unduly
consume what otherwise would be shared. Moreover, neither this LEO system’s licensing
administration nor the LEO operator itself has identified what parameters would have to be
satisfied to safely allow other LEO satellites or constellations to occupy, or overlap, the
orbits this LEO system plans to occupy. And other LEO operators have asserted to the
contrary that LEO systems cannot safely share the same orbits.
Again, this LEO operator could therefore hinder the ability of other satellite operators,
including new entrants, to access and use the same shared spectrum and orbital resources
in the public interest. This operator already enjoys the ability to use LEO regardless of
whether physical coordination with any other operator is concluded successfully but the
same cannot be said with respect to new entrants (i.e., beyond those already deploying LEO
systems) which may be deterred from even attempting to deploy systems that overlap with
this LEO system.

One mitigation would be to require any LEO operator serving a country to maintain an
orbital tolerance of +/- 2.5 km for the apogee and perigee of each satellite, and a 0.5o
tolerance for each orbital inclination it employs, to ensure other LEO systems that seek to
serve the country may access the shared LEO space, or alternatively to apply such orbital
tolerance requirements as the national regulator deems appropriate to ensure the ability of
http://www.viasat.com 15
other satellites and systems serving that country to safely operate within, or overlap, the
orbits occupied by large LEO constellations. Such an approach is depicted in Figure 4 below.
Figure 4: Reasonable orbital tolerances leave room for many LEO systems
D. Consuming more than an equitable share of the aggregate EPFD limit for all NGSO
systems
As explained in Annex A, one LEO operator plans to operate its system under multiple ITU
filings that would result in its system significantly exceeding the ITU’s aggregate EPFD limits.
In addition to that one system causing far more interference into GSO networks than is
permitted by ITU Radio Regulations, it would hinder opportunities for other parties,
including national operators, to operate their own NGSO systems, because that one system
would consume (and in fact would exceed) the entire aggregate EPFD “budget” that must be
apportioned among all NGSO systems using the same or overlapping frequencies.
And even if that LEO system did not consume the entire aggregate EPFD budget, by virtue of
claiming rights to operate under many different ITU filings, the operator of that LEO system
would have significant leverage against other NGSO systems in any negotiations that must
occur over the allocation of the aggregate EPFD “budget” among multiple NGSO systems.
III. Adverse impact on national space industries
A leading position by one or two LEO operators with respect to NGSO resources could not
only hinder the ability of other satellite operators or constellation projects to operate
effectively, it also would represent a loss in value for national satellite communications
infrastructures in both the public and the private sectors. This includes space industry
players as diverse as manufacturers, launch operators, and national satellite programs for
both communications and other LEO applications.
http://www.viasat.com 16

Particularly coupled with one NGSO operators’ control over critical launch vehicles, the
possibility of these harms is easy to envision.
The loss in value for national economies and the corresponding negative impact on jobs
would be tremendous. National regulators should ensure the continued relevance of their
existing national industrial bases, as well as all new domestic companies looking to take
advantage of opportunities presented in the new space era that depend on access to
spectrum and orbital resources.
A growing recognition exists that there are constraints on the exploitation of LEO, which
have been expressed alternatively as environmental limits,19 “carrying capacity,”20 and
“time to Kessler Syndrome.”21 Regardless of the terminology, the critical point is that LEO
(like all NGSO) orbital resources are limited. As one leading expert explains:
I think we are going to lose the ability to use certain orbits because the carrying
capacity is going to get saturated by objects and junk. Orbital capacity being
saturated means “when our decisions and actions can no longer prevent undesired
outcomes from occurring.”22
It therefore is incumbent on national regulators to consider what portion of these resources
– including spectral resources – NGSO systems that are permitted to serve their countries
would consume, and what portion would remain available for domestic participants in the
space and telecom industry.

19 See, e.g., European Space Policy Institute, ESPI Report 82 – Space Environment Capacity – Full Report (Apr.
2022), https://espi.or.at/news/espi-report-82-space-environment-capacity; L. Miraux, “Environmental
Limits to the Space Sector’s Growth,” SCIENCE OF THE TOTAL ENVIRONMENT (Feb. 2022),
https://www.sciencedirect.com/science/article/abs/pii/S0048969721059404?via%3Dihub (“A common
assumption is that limitations to the human enterprise in space are of a purely technical land economic
nature. This paper challenges this assumption, by highlighting the existence of environmental limits to the
currently planned development of space activities. Risks arising from these limits are explored, and the
importance of eco-design in the space sector is emphasized.”); A. Boley & M. Byers, Satellite MegaConstellations Create Risks in Low Earth Orbit, Sci Rep 11, 10642 (2021), at 1-3,
https://doi.org/10.1038/s41598-021-89909-7.
20 See Physics Today, Toni Feder, “Q&A: Moriba Jah on sustainability of near-Earth space,” (Mar. 31, 2022),
https://physicstoday.scitation.org/do/10.1063/PT.6.4.20220331a/full/.
21 See M. A. Sturza and G. Saura Carretero, 2021 Advanced Maui Optical and Space Surveillance Technologies
Conference (AMOS), “Design Trades for Environmentally Friendly Broadband LEO Satellite Systems,”
(2021), https://amostech.com/TechnicalPapers/2021/Poster/Sturza.pdf.
22 E. Berger, “Space debris expert: Orbits will be lost—and people will die—later this decade. Flexing
geopolitical muscles in space to harm others has already happened,” Ars Technica (Dec. 14, 2022)
(quoting Moriba Jah), https://arstechnica.com/science/2022/12/space-debris-expert-orbits-will-be-lostand-people-will-die-later-this-decade/.
http://www.viasat.com 17
IV. Adverse consequences on end-users and citizens
National economies and societies are increasingly reliant on space services (such as location
services, satellite-based media services, weather forecasting and emergency services). This
growing reliance of national economic activities on space comes with the need to avoid and
mitigate risks of disruption to space-based assets and infrastructure.
The increase in number of space objects – from 2,000 active satellites in late 2018 to
approximately 4,000 today and likely 100,000 or more by the end of the decade – a growing
amount of orbital debris, and the resulting growing congestion of LEO, increases the
likelihood of collision events that can disable and even destroy satellites, and also generate
more orbital debris.23 Each collision will statistically lead to more collisions and ultimately
can lead to a “belt of debris around the Earth,”24 resulting in a series of self-sustaining
collisions referred to as the Kessler syndrome, which could make certain orbits unusable for
critical civic, military and commercial space services.
One notable study commissioned by the U.S. National Science Foundation (NSF) indicates
that it may not be feasible to sustain the deployment of one large NGSO system over time
because of these dynamics. That NSF study forecasts a dramatic increase in both space
collisions and new debris, starting within just a few years; in the longer term, “satellites are
destroyed [by collisions with debris] faster than they are launched.”25 Another study
concludes that “Kessler Syndrome is expected to occur in low-Earth orbit around 2048
under recent historical sectoral growth trends, and may occur as early as 2035 if the space
economy grows consistent with projections by major investment banks.”26
Notably, the massive increase in LEO constellation sizes is driving an exponential increase in
the number of conjunctions (i.e., “close calls”) that a given constellation can be expected to
experience over time—dramatically increasing the likelihood of an in-orbit collision that
would have devastating impacts on space sustainability and safety.27 As one leading expert
explains: “The law of very large numbers will tell you that very low probability events can

23 See A. Lawrence, M. L. Rawls, M. Jah, A. Boley, F. Di Vruno, S. Garrington, M. Kramer, S. Lawler, J.
Lowenthal, J. McDowell, and M. McCaughrean, “The case for space environmentalism,” NATURE
ASTRONOMY (Apr. 22, 2022), https://www.nature.com/articles/s41550-022-01655-6.
24 See D. J. Kessler and B. G. Cour-Palais, “Collision Frequency of Artificial Satellites: The Creation of a Debris
Belt” (1978).
25 G. Long, “The Impacts of Large Constellations of Satellites,” JASON – The MITRE Corporation, JSR-20-2H,
Nov. 2020, (Updated: Jan. 21, 2021), at 97,
https://www.nsf.gov/news/special_reports/jasonreportconstellations/JSR-20-
2H_The_Impacts_of_Large_Constellations_of_Satellites_508.pdf.
26 A. Rao and G. Rondina, “Open access to orbit and runaway space debris growth,” arXiv:2202.07442
[econ.GN] (Feb. 16, 2022), at 1, https://arxiv.org/pdf/2202.07442.pdf.
27 See Comments of NASA, U.S. FCC IBFS File No. SAT-AMD-20210818-00105, at 1 (filed Feb. 8, 2022) (“NASA
Letter”) (With the increase in large constellation proposals to the FCC, NASA has concerns with the
potential for a significant increase in the frequency of conjunction events and possible impacts to NASA’s
science and human spaceflight missions.”); (“An increase of this magnitude into these confined altitude
bands inherently brings additional risk of debris-generating collision events based on the number of
objects alone.) (emphasis added).
http://www.viasat.com 18
happen if given enough opportunities.”28 However, no current rules or guidelines reflect
the magnitude of these dangers.
The collision risk is further exacerbated by the documented failure rates of satellites in
certain LEO constellations: indeed, satellites that cannot maneuver cannot avoid collisions,
and experiential failure rates early in the life on one constellation demonstrates that it has
not been capable of maintaining a sufficiently low level of disposal reliability.29 Moreover,
all potential collisions cannot be predicted, and even where a satellite is maneuverable, all
potential collisions cannot be avoided.30
These points are particularly relevant in light of recent attention to the short-term and longterm consequences of a successful anti-satellite (ASAT) test that occurred in November 2021
with the Cosmos 1408 satellite. Another recent study shows that a similar result can be
expected should two large LEO satellites collide catastrophically.31 Both types of events
generate large numbers of lethal debris that spread into orbits hundreds of kilometers away
from the point of impact and persist for decades,32 including lethal, non-trackable debris
(LNT), that (i) increase the risk of spacecraft collisions (and human casualties in space), (ii)
cannot be seen and thus cannot be avoided, and the risks of which cannot otherwise be
mitigated today, and (iii) can destroy or disable active satellites and thus disrupt vital
satellite-based services. In fact, experts explain that LNT “dominates the risk profile of
operational spacecraft.”33
Failures and collisions of this sort would affect far more than the satellites in the LEO
constellation itself. Failed LEO satellites, collisions involving LEO satellites, and the resulting
debris fields, would affect all individual satellites and constellations that occupy, or transit,
the same or overlapping orbits, potentially disrupting the operation of other critical satellite
systems, including those in LEO and beyond. And both failed satellites and catastrophic
collisions would make the orbital environment more crowded and dangerous and make
access to space more costly and risky for others—including satellites that provide DTH video
and broadband communications services, as well as those that provide critical space-based
observations for weather forecasting, climate monitoring, and earth sciences, and PNT.

28 https://twitter.com/ProfHughLewis/status/1509903335251456045 (Apr. 1, 2022).
29 See “Jonathan’s Space Pages: Starlink Statistics,” https://planet4589.org/space/con/star/stats.html
(detailing a variety of types of failures and anomalies involving Starlink satellites).
30 See NASA Letter at 3 (“[C]onsidering multiple independent constellations of tens of thousands of
spacecrafts and the expected increase in the number of close encounters over time, the assumption of
zero risk from a system-level standpoint lacks statistical substantiation.”) (emphasis added).
31 “Satellite Collisions Have the Same Consequences as ASAT Tests” (Nov. 2021),
https://www.viasat.com/space-innovation/space-policy/space-debris/.
32 See “Self-Cleaning Orbit Myth” (Dec. 2021), https://www.viasat.com/space-innovation/spacepolicy/space-debris/.
33 R. Buchs, “Collision risk from space debris: Current status, challenges and response strategies,” Lausanne:
EPFL International Risk Governance Center (2021), at 13, https://go.epfl.ch/irgc_space_debris_report
(“LNT objects dominate the risk profile of operational spacecraft. As they are far more numerous than
trackable objects and cannot be avoided, LNT objects make up more than 95% of the mission terminating
collisional risk for a typical LEO satellite[.]”).
http://www.viasat.com 19
These harms also include the costs and risks related to designing NGSO satellite and
constellations to operate in a more crowded (and dangerous) environment, the risks and
delays associated with launching satellites into and through those crowded environments
(i.e., on the way to higher orbits, including GSO orbit), and the risks associated with
deorbiting satellites through those crowded orbits at end of life.
Moreover, as observed by both the Chief Executive Officer of one satellite launch provider,34
and NASA,35 the crowding of LEO from the active satellites of one large LEO constellation
alone would reduce the number of viable launch windows available, and thus increase the
costs and delay associated with launch activities of all types, for all satellites in all orbits.
Furthermore, in a landmark report, the Organization for Economic Cooperation and
Development (OECD) points to the growing risk of an irreversible environmental and
industrial disaster in space.36 The deployment of large LEO constellations outside a clear
framework and regulation for the preservation of LEO therefore poses a potential direct
threat to the function of key space-based systems that are coming online now and from
which many countries may derive benefit in the future, such as GPS systems, which in turn
“would have a direct impact upon the security, safety, economy and well-being” of
citizens.37
Collision and orbital debris generation risks also are materially affected by the mass and
cross-sectional area of LEO satellites, as well as by the number of satellites in a constellation
and the particular orbits they employ.38 In what is a disturbing trend, LEO spacecraft are
becoming larger and more massive, with significant implications for the space sustainability
and safety risks posed by individual satellites, even when viewed in isolation (e.g., persatellite collision risks), due to increased collision risk associated with greater cross-sectional
area, and the larger resulting debris fields when these more massive satellites collide with
other space objects.

34 J. Wattles, “Space is becoming too crowded,” Rocket Lab CEO Warns, CNN (Oct. 8, 2020),
https://www.cnn.com/2020/10/07/business/rocket-lab-debris-launch-traffic-scn/index.html (“Satellite
constellations can be particularly problematic,” he said, “because the satellites can fly fairly close
together, forming a sort of blockade that can prevent rockets from squeezing through.”).
35 NASA Letter at 4 (“NASA is also concerned with an increasing unavailability of safe launch windows,
especially for missions requiring instantaneous or short launch windows, such as planetary missions like
Europa Clipper, which would be significantly affected due to a lost launch opportunity.”)
36 “Space Sustainability: The Economics of Space Debris in Perspective,” OECD Science, Technology and
Industry, Policy Papers, No. 87 (Apr. 2020), https://www.oecd.org/fr/environnement/space-sustainabilitya339de43-en.htm.
37 European Commission, Joint Communication to the European Parliament and the Council, “An EU
Approach for Space traffic Management; An EU contribution addressing a global challenge” (Feb. 15,
2022), https://ec.europa.eu/info/sites/default/files/join_2022_4_1_en_act_part1_v6.pdf.
38 See M. A. Sturza and G. Saura Carretero, 2021 Advanced Maui Optical and Space Surveillance Technologies
Conference (AMOS), “Design trades for Environmentally Friendly Broadband LEO Satellite Systems”
(2021), https://amostech.com/TechnicalPapers/2021/Poster/Sturza.pdf.
http://www.viasat.com 20
The dramatic increase in satellite mass and cross-sectional area in LEO satellite designs is
illustrated in the Figure 5. As discussed below, this trend has serious repercussions for others
who seek to access and use space.
Figure 5: Trends in estimated LEO spacecraft mass and cross-sectional area
National regulators therefore should: (i) require LEO applicants to disclose the mass and
cross-sectional area of proposed LEO satellites, in addition to the number of satellites in a
constellation and the particular orbits they employ, so the aggregate risk presented by the
constellation can be evaluated, and (ii) require that an applicant not make changes that
increase the mass or cross-sectional area of its satellites, the number of its satellites, or the
orbits it plans to use, without providing notice to and obtaining approval from the national
regulator. This information is essential to allow the calculation and management of a LEO
constellation’s total contribution to collision and orbital debris risk.
A very significant and positive development is reflected in the modeling (based on empirical
measurement tools and quantitative analyses) that has been developed to help (i)
understand the limits to LEO space exploitation and how we best can operate within those
limits, and (ii) make more informed policy making and licensing decisions.
A recent study entitled “LEO Capacity Modeling for Sustainable Design”39 estimates LEO
“carrying capacity”, that is, the sustainable satellite population distribution in LEO. It
estimates future debris propagation, considering both existing debris and the likelihood that
non-debris objects become debris within a given time horizon. It also accounts for the
performances of various possible mitigations. This methodology enables holistically
comparing contributions to debris propagation as a function of specific system

39 M. Sturza, M. Dankberg, W. Blount, “LEO Capacity Modelling for Sustainable Design,” Advanced Maui
Optical and Space Surveillance Technologies Conference, Sept. 27-30, 2022,
https://amostech.com/TechnicalPapers/2022/Space-Debris/Sturza.pdf.
http://www.viasat.com 21
characteristics and deducing the incremental impact of individual systems and
characteristics on LEO carrying capacity.
This study yields many significant results, including: (i) the proposed second-generation
configurations of two particular mega-constellation would consume all, or nearly all, of the
carrying capacity in LEO orbits neighboring those occupied by those constellations; (ii) less
massive satellites with smaller cross-sectional area facilitate greater carrying capacity in
LEO; and (iii) removing the existing population of derelict rocket bodies does not result in a
material increase in LEO carrying capacity.
These results highlight the need to facilitate sustainable use of LEO by: (i) applying orbital
admittance control and minimum satellite reliability requirements through license and
market access conditions that limit the number of LEO satellites, mass, and cross-sectional
area launched into various orbits, and ensure a certain probability of successful post-mission
disposal; and (ii) developing suitable orbital regimes to support different types of LEO
systems. For example, (a) altitudes below 400 km may be suitable for non-propulsive
satellites; (b) altitudes in the 400 km to 600 km range may be suitable for megaconstellations (provided that the number of satellites, mass, and cross-sectional area
launched are managed); and (c) smaller constellations above 600 km are likely sustainable
depending on mass and cross-sectional area.
Significantly, the model underlying this study is useful in: (i) assisting in the design of
sustainable broadband LEO systems; (ii) assessing the impact of existing and planned LEO
systems; and (iii) understanding the implications of multiple large LEO constellations
occupying neighboring, interleaving, or overlapping orbits.
Moreover, using such a model can facilitate: (i) quantitatively measuring absolute and
relative effectiveness of candidate regulations and policies governing space access and
operations, and determining the effectiveness of remediations and mitigations such as
debris removal strategies, Space Surveillance and Tracking (SST), Space Situational
Awareness (SSA), and Space traffic Management (STM); (ii) considering interactions among
all missions and constellations, instead of merely addressing each one individually and
based on historical debris flux models; and (iii) fostering identification of quantitative
system design characteristics that slow, halt, or reverse acceleration towards a point in time
when access to space is intolerably impaired or even lost.
Thus, this type of model provides a quantitative alternative to intuitive heuristics and
mitigations currently being contemplated to address the debris crisis and thus should
provide for more informed policy making and licensing decisions.
http://www.viasat.com 22
V. Adverse environmental effects on the atmosphere, astronomy, and the night sky
The increased use of space is not without cost to the environment. The rapid development
of large LEO constellations risks multiple tragedies of the commons, including tragedies to
ground-based astronomy, life on Earth, and Earth’s upper atmosphere.40 Those costs
include: (i) the potential for large quantities of satellites reentering the atmosphere to
damage the Earth’s atmosphere and effect climate change through, among other things,
radiative forcing41 and depletion of the ozone layer, increasing the risk of cancer and other
negative health effects;
42 (ii) impairing critical optical and radio astronomical research by
disrupting the visible night sky;
43 (iii) creating light pollution, with the resulting negative

40 See A. Lawrence, M. L. Rawls, M. Jah, A. Boley, F. Di Vruno, S. Garrington, M. Kramer, S. Lawler, J.
Lowenthal, J. McDowell, and M. McCaughrean, “The case for space environmentalism,” NATURE
ASTRONOMY (Apr. 22, 2022), https://www.nature.com/articles/s41550-022-01655-6;
Letter from Natural Resources Defense Council and the International Dark-Sky Association to U.S. FCC,
IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD-20210818-00105 (Sep. 7, 2022) (“NRDC & IDA
Letter”);
A.C. Boley, and M. Byers, “Satellite mega-constellations create risks in Low Earth Orbit, the atmosphere
and on Earth,” SCIENTIFIC REPORTS, 11, Article number 10642 (May 20, 2021),
https://www.nature.com/articles/s41598-021-89909-7.
41 See L. Organski, C. Barber, S. Barkfelt, M. Hobbs, R. Nakagawa, Dr. M. Ross, Dr. W. Ailor, “Environmental
Impacts of Satellites from Launch to Deorbit and the Green New Deal for the Space Enterprise,” Aerospace
Corporation (Dec. 2020);
D. Werner, “Aerospace Corp. Raises Questions about Pollutants Produced during Satellite and Rocket
Reentry,” SpaceNews (Dec. 15, 2020), https://spacenews.com/aerospace-agu-reentry-pollution/;
M. N. Ross & L. David, “An Underappreciated Danger of the New Space Age: Global Air Pollution,”
Scientific American (Feb. 2021), https://www.scientificamerican.com/article/an-underappreciated-dangerof-the-new-space-age-global-air-pollution/;
M. N. Ross and K. L. Jones, “Implications of a growing spaceflight industry: Climate change,” JOURNAL OF
SPACE SAFETY ENGINEERING (Jun. 6, 2022),
https://www.sciencedirect.com/science/article/abs/pii/S2468896722000386;
U.S. Government Accountability Office, Large Constellations of Satellites: Mitigating Environmental and
Other Effects, GAO-22-105166 (Sep. 29, 2022) (“First U.S. GAO Report”),
https://www.gao.gov/products/gao-22-105166.
42 See NRDC & IDA Letter at 3.
43 See R. Boyle, “Satellite Constellations Are an Existential Threat for Astronomy,” Scientific American (Nov.
7, 2022), https://www.scientificamerican.com/article/satellite-constellations-are-an-existential-threat-forastronomy/;
A. Lawrence, M. L. Rawls, M. Jah, A. Boley, F. Di Vruno, S. Garrington, M. Kramer, S. Lawler, J. Lowenthal, J.
McDowell, and M. McCaughrean, “The case for space environmentalism,” NATURE ASTRONOMY (Apr. 22,
2022), https://www.nature.com/articles/s41550-022-01655-6;
C. Young, “The worst case Starlink scenario? We could be ‘right on the edge’ of Kessler syndrome,”
INTERESTING ENGINEERING (Aug. 11, 2022), https://interestingengineering.com/innovation/worst-casestarlink-scenario-kessler-syndrome;
First U.S. GAO Report at 1;
United Nations Office for Outer Space Affairs, International Astronomical Union, IAC, NOIR Lab, Dark and
Quiet Skies for Science and Society: Report and Recommendations, (Dec. 29, 2020), available at
https://www.iau.org/static/publications/dqskies-book-29-12-20.pdf.
http://www.viasat.com 23
impacts on the health and quality of life of humans and on plants and animals;
44 and (iv) as
NASA has emphasized, impairing the functioning of critical asteroid detection and defense
capabilities.45
In fact, certain choices made in LEO system design are the dominant factors affecting these
additional impacts, such as satellite cross-sectional area, mass, orbit, and number of
satellites, along with albedo (or reflectivity) and material composition.
We are trending the wrong way in each of these respects as depicted in Figure 6, which
shows the: (i) total number of satellites in LEO as of January 1, 2022,
46 as well as the
associated mass and cross-sectional area of those satellites (in green); and (ii) the
exponential increase in these values that would occur if merely one particular LEO system
were allowed to deploy (in red).47
Figure 6: Trends in LEO constellation size, mass, and cross-sectional area
Expert review confirms that the decades-old approach being applied by some to the
environmental effects of today’s mega-constellations must be revisited to account for the
new information that is available about those never-before-contemplated effects.48 It is
essential that these effects be taken into consideration when evaluating what types of LEO
constellations are authorized to serve a given country.

44 NRDC & IDA letter at 3.
45 See NASA Letter at 3 (“[T]here would be a Starlink in every single asteroid survey image taken for
planetary defence against hazardous asteroid impacts, decreasing asteroid survey effectiveness by
rendering portions of images unusable. This could … have a detrimental effect on our planet’s ability to
detect and possibly redirect a potentially catastrophic impact.”) (emphasis added).
46 See ESA’s Annual Space Environment Report, at 52-54 (Apr. 22, 2022),
https://www.sdo.esoc.esa.int/environment_report/Space_Environment_Report_latest.pdf (providing
data used for Jan. 1, 2022 “baseline”).
47 Based on data SpaceX provided to the U.S. FCC in its proposal to expand its system.
48 See U.S. Government Accountability Office, FCC Should Reexamine Its Environmental Review Process for
Large Constellations of Satellites, GAO-23-105005 (Nov. 2022), at 28, https://www.gao.gov/products/gao23-105005.
http://www.viasat.com 24
The environmental consequences of the proposed expansion of one large LEO system—
which is unprecedented in nature and would involve deploying approximately 90,000 (or
more) total satellites over 15 years, using a launch every six days—would be grave.49
Among other things, the impact of depositing an estimated 150,000 tons of alumina into the
upper atmosphere when its satellites deorbit50 would certainly have deleterious effects.
And the facts (including those provided by NASA) reflect that this operator is not protecting
astronomy or preserving the night sky, and this operator has not shown how it would do so
with an expanded system incorporating an additional 30,000 operating satellites.51
Moreover, an increase in the number of failed NGSO satellites, catastrophic collisions
involving NGSO (for any reason), and the resulting orbital debris fields, would make the
orbital environment more crowded and dangerous, and risk the irreversible environmental
disaster in space about which OECD warns (see section IV above).
VI. Implications for national security
Space is a vital component of any drive towards the strategic autonomy of any nation, as it
helps with situational awareness, decision-making and connectivity of technologies and
systems, including with national security and defense applications.
The recent ASAT test shows that hostile activities by sovereign actors in space represent a
very significant threat to open and safe space. The same can be said of the risk that space
activities carried out by private actors represent to all space actors, including the generation
of a massive number of additional space objects and the corresponding risk of collisions
leading to debris creation and possibly to a Kessler Syndrome (see section IV above). As
noted above, according to an evaluation of the debris generated by that ASAT test, a
collision between two NGSO satellites would generate a similar dispersion of lethal
trackable and non-trackable debris in space.52 Orbits made unusable by space debris would

49 See J. Baumgartner, “Starlink’s daunting deployment plan ‘leaves no margin for error’ – analyst,”
BROADBAND WORLD NEWS (Jan. 18, 2022),
https://www.broadbandworldnews.com/author.asp?section_id=733&doc_id=774668, citing “Starlink: Go
Big or Go Home,” MOFFETTNATHANSON (Jan. 18, 2022). “Even using Starship, at 100 satellites per launch,
achieving a 30,000-bird constellation and sustaining it through, say, 2030, would require launching fifty
thousand satellites, or five hundred rockets, between now and then,” Moffett estimates. “That’s a rocket
launch roughly every six days… for nine years. Simply maintaining the constellation thereafter, if one
assumes 20% annual attrition (de-orbiting), would require a new launch every six days. Forever.”
50 Based on SpaceX’s prior representation that 1st generation Starlink satellites “consist of approximately 230
pounds of aluminium” and that there is a “52% mass fraction aluminium” in alumina (Al2O3)., then 29,988
x 230 / 0.52 = 13,263,923 pounds. Factoring in replacements for those Gen2 satellites over a 15-year
license term and that Gen2 satellites may be almost eight times more massive, the proposed Starlink
expansion could well result in SpaceX releasing about 150,000 tons of additional alumina beyond the Gen1
amounts into the upper atmosphere.
51 See Scientific Reports, “Satellite mega-constellations create risks in Low Earth Orbit, the atmosphere and
on Earth,” Article number 10642 (May 20, 2021), https://www.nature.com/articles/s41598-021-89909-7.
52 “Satellite Collisions Have the Same Consequences as ASAT Tests” (Nov. 2021),
https://www.viasat.com/space-innovation/space-policy/space-debris/.
http://www.viasat.com 25
adversely affect defense and security applications the same way as they would affect civil
and commercial use cases.
Moreover, the risk of business failure in this new environment is high, and business failures
can leave an operator with neither the ability nor the incentive to promptly deorbit failed
satellites, increasing the risk for everyone else.
Countries, through their national regulators, should be particularly mindful of the risk that
‘out-of-scale’ projects in LEO like certain large NGSO constellations could pose to their
sovereign activities in and from space.
VII. Recommendations
As the pace of space activities accelerates and societies become even more reliant on spacebased systems, the associated risks to the public interest and national and regional space
industries deserve immediate attention, including in licensing and market access decisions.
To mitigate the risks and costs discussed above, national regulators should conduct an
independent assessment of these matters and impose suitable conditions on both NGSO
spectrum authorizations and grants of market access, including the following:
A. Protect GSO networks from unacceptable interfence generated by NGSO systems,
including by requiring:

• An NGSO system to comply with single-entry EPFD limits across the entirety of the
  the system, with the national regulator viewing all NGSO system filings under which
  an NGSO system operates as a collective;
   In other words, require that an NGSO system operate such that it does not
  exceed any of the EPFD limits established for an individual NGSO system, just as
  if it were relying on a single ITU filing for all co-frequency operations;
• An NGSO operator to provide, as part of the application process:
   The number of satellite beams used for transmissions on the same frequency
  in the same or overlapping areas at any given time;
   A demonstration how the NGSO system avoids interference to GSO networks
  created by earth station and satellite antenna sidelobes, and earth station
  antenna backlobes, particularly when phased array antennas are employed;
  and
   An examinination of the interference cases within the national territories of
  the regulator that are not tested by the limited examination conducted by
  the ITU (with the regulator verifying that showing with its own analysis);
• An NGSO system to maintain a suitable GSO arc avoidance angle when serving its
  territory, taking into account the actual characteristics of affected GSO networks
  (such as satellite receiver noise temperature and antenna gain, and sizes and
  characteristics of user terminals);
• NGSO systems not to cause unacceptable interference into GSO networks and not to
  claim interference protection from GSO networks;
  http://www.viasat.com 26
• NGSO systems to have an operational feature that allows them to immediately
  interrupt radio frequency emissions to ensure satisfaction of this non-interference
  requirement, and to cease emissions upon notice of unacceptable interference;
• If interference into a GSO network occurs, NGSO systems to cease operations and
  not recommence operations until they address the cause of such interference by,
  among other things, increasing angular separation, reducing power, shaping antenna
  beams differently;
• All NGSO systems serving a given country, as a collective, not to exceed aggregate
  EPFD limits; and
• If aggregate interference to a GSO network from signals transmitted by multiple
  NGSO systems is detected, and it is not possible to identify the NGSO system
  generating the interference, that NGSO system operators cooperate with each other
  and take the technical measures necessary to eliminate the interference.
  B. Ensure NGSOs share frequencies and orbits with other NGSOs, including by requiring:
• NGSO systems to constrain the ability to hinder use of limited and shared NGSO
  orbital resources by others by:
   Operating with only 1/n of the look angles in a given country, where n is the
  number of NGSO systems authorised to serve that country in the same frequency
  band;
   Coordinating in good faith and in advance with other NGSO systems so that all n
  look angles may be used to serve that country by different NGSO systems; and
   Maintaining an orbital tolerance of +/- 2.5 km for the apogee and perigee of each
  NGSO satellite, and a 0.5° tolerance for each orbital inclination the NGSO system
  employs, in order to ensure other NGSO systems may access the shared LEO
  space (or comply with such other orbital tolerance requirements as the national
  regulator deems appropriate to ensure the ability of other satellites and systems
  serving its territory to operate in the same, or overlapping, orbits occupied by
  the NGSO system).
  C. Ensure space safety and sustainability by managing the aggregate collision risk of the
  entirety of an NGSO system for the full orbital life of each satellite, and as system
  characteristics and the orbital environment may change, including by:
• Evaluating the entirety of collision risk created by all of the satellites in a large NGSO
  system as a whole, taking into account:
   Risks during the entire period each satellite in the constellation remains in orbit
  and at all orbits it may populate (injection, operational, and post mission
  disposal);
   Increased risk of collisions due to changes in the orbital environment (such as
  satellites breaking up/exploding, debris colliding with other debris and breaking
  up further, and deployment of additional NGSO systems—not just the
  environment as it existed in the past);
   Characteristics of the NGSO system—numbers of satellites, orbits used, total
  cross-sectional area and mass of all of the satellites, subsystem reliability,
  http://www.viasat.com 27
  redundancy, shielding, and operational techniques to reduce risk of system
  failures—and any subsequent proposed changes to those parameters.
• Taking into account in an NGSO system’s aggregate collision risk analysis:
   Orbital tolerances employed, both altitude and inclination;
   Risk of collisions with all sizes of space objects, whether trackable or not,
  including lethal non-trackable objects;
   Continued reliability of critical command and propulsion capabilities needed to
  try to maneuver to avoid collisions—and probability that those critical systems
  may be damaged by untrackable debris too small to fragment the satellite
  (considering early life failure rates where available);
   Numbers of satellites that have failed/lost maneuverability;
   Means to coordinate collision avoidance with other satellite systems;
   Risk of intra-system collisions within the NGSO constellation (due to all causes,
  including failed satellites, within that system);
   Known risks with large numbers (potentially millions per year) of expected
  conjunctions between a large NGSO system and other space objects (e.g., large
  numbers of maneuvers to avoid some collisions create other collision risks);
   Interactions of all satellites in a large NGSO system with all other objects in their
  environment (including overlapping and intersecting orbits) during orbit raising
  maneuvers for rising satellites, considering active and passive decay trajectories
  for satellites in the orbital disposal phase, as well as active in-service satellites.
• Avoiding the application of simplifying assumptions, such as:
   Existence of purported “self-cleaning orbits”;
   Efficacy of “autonomous” controls in avoiding collisions; and
   Fallacy that maneuverable satellites have “zero risk” of collision.
  D. Adopt suitable conditions to address the types of environmental harms discussed above
  regarding the Earth’s atmosphere, a dark sky, and radio and optical astronomy.
  E. Require that an NGSO operator not modify the characteristics of its LEO system (radio
  frequency, avoidance angle, orbital characteristics, number of satellites, or satellite crosssectional area or mass) without prior consent from a national regulator (in order to
  maintain its authorizations in the country).
  F. Require each NGSO system to provide, every six months, a report showing compliance
  with the obligations attached to the authorizations granted.
  ANNEX A:
  Examples of Violations of EPFD↓ Limits (Fuchsstadt, Germany)
  http://www.viasat.com 29
  Annex A: Examples of Violations of EPFD↓ Limits (Fuchsstadt,
  Germany)
  This analysis calculates exceedances of ITU interference limits for the first and second
  generation Starlink configurations, based on the guidance provided in ITU-R
  Recommendation S.1503-3. It assesses the expected levels of interference generated by the
  Starlink system with respect to an earth station location at Fuchsstadt, Germany (50.118°N.
  9.924°E) communicating with geostationary orbit (GSO) satellites serving Germany, located
  at 17.6°E longitude (H2M-17.6E) operating in both Ku and Ka-bands.
  A-I. Background
  The ITU has established permissible levels of interference into GSO networks from non-GSO
  systems, like Starlink, in Article 22 of the ITU Radio Regulations. Exceeding these levels
  would violate the Radio Regulation 22.2 requirement that:
  “Non-geostationary-satellite systems shall not cause unacceptable interference to []
  geostationary-satellite networks in the fixed-satellite service and the broadcastingsatellite service operating in accordance with these Regulations.”
  These interference limits are specified as single-entry equivalent power flux density
  downlink (EPFD↓) limits for individual non-GSO systems (in Tables 22-1A and 22-1B for the
  FSS and in Table 22-1D for the BSS), and EPFD↓ limits for all non-GSO systems of all
  operators considered together (in ITU Resolution 76).
  The limits are specified as cumulative distribution function (cdf) curves. Each limit curve is
  defined, for a reference bandwidth and a reference antenna diameter, by a series of points,
  EPFD↓ (dBW/m2
  ) values and associated values for percentages of time during which EPFD↓
  may not be exceeded. The complete limit curves are obtained by interpolating between
  those points.53 Thus for any EPFD↓ value, there is a percentage of time that value may not
  be exceeded. Similarly, for each percentage of time from 0% to 100%, there is an EPFD↓
  value that may not be exceeded.
  Any exceedance of those EPFD↓ levels—whether for the 100% of time value, the 10% value,
  the 1% value, or for any other percentage of time value—is a violation of the ITU Radio
  Regulations and has the potential to result in interference into GSO networks that degrades
  service and causes capacity losses. This includes GSO direct-to-home television and BSS
  networks as well as broadband GSO FSS networks.
  Based on the data provided in a given ITU EPFD input filing (consisting of SRS and Mask
  databases), the ITU’s Radiocommunication Bureau (BR) does a limited assessment of the
  EPFD levels that may be generated by a non-GSO system with respect to one particular

53 RR 22.5C.5 For each reference antenna diameter, the limit consists of the complete curve on a plot which
is linear (dB) for the epfd↓ levels and logarithmic for the time percentages, with straight lines joining the
data points.
http://www.viasat.com 30
combination of earth station location and GSO satellite location. This “examination” uses a
software package developed in collaboration with Transfinite to calculate expected EPFD
levels that would be produced with respect to that particular non-GSO satellite filing in
those limited circumstances. As explained below, those limited circumstances have little
bearing on the interference that Starlink can be expected to produce in Germany.
The BR’s examination is actually a limited spot check, based on the “worst-case geometry”
(WCG), one particular GSO earth station (ES) location and one particular GSO satellite
location, which is identified as the geometry maximizing the instantaneous non-GSO EPFD↓
level for a specific case of the Table 22 limits (service, frequency, antenna diameter, and
radiation pattern).54 That maximum EPFD↓ value is typically produced for a very short
period of time, and thus lies at the bottom-right corner of the relevant EPFD↓ cdf curve (i.e.,
the alignment of the non-GSO system with the GSO orbital location that produces the
highest instantaneous interference level—for a very small percentage of the time, typically
on the order of 0.001%, or less). This examination does not consider the ability of a nonGSO system to satisfy EPFD↓ limits at any other GSO ES location or with respect to any other
GSO orbital location.
Further, the ITU does not evaluate the ability of a non-GSO operator to actually operate in a
manner consistent with the operator supplied EPFD input data, and concerns have been
raised that some inputs in the data files provided to the ITU are inconsistent with the laws
of physics. Critically, it ultimately falls on the non-GSO system operator to actually conduct
its operations in full compliance with all EPFD↓ limits, regardless of any limited evaluation
initially conducted by the ITU. Moreover, it is difficult to attribute interference to a
particular non-GSO system once it is in operation, particularly when more than one nonGSO system operates in the same or overlapping frequencies. Some of these factors are
why the French space agency, CNES, has recommended that frequency regulators require
applicants to provide more detailed information that allows an analysis of foreseeable
interference with other systems, existing or future.55
Critically, EPFD↓ levels calculated for geometries other than the one identified by the WGC
algorithm in ITU-R Recommendation S.1503 that is implemented in the Transfinite software
can exceed the relevant EPFD↓ limit cdf curve at any point. Specifically, this can occur at
different GSO ES locations on Earth, and with different GSO satellite locations, than those
identified by the S.1503 WCG algorithm. An analysis at those other geometries can be
conducted with Transfinite’s commercially available Visualyse EPFD software, which uses
the same algorithm and EPFD calculation engine as in the software it developed for the ITU,
with an added feature that allows the geometry (GSO ES location and GSO satellite location)
to be set manually, so that compliance with all EPFD limits, at all GSO ES locations and for all
GSO satellite locations can be evaluated. This is particularly valuable when an examination
is desired of the expected interference into GSO services in a given country, or into one of
its GSO satellite networks.

54 See generally ITU-R Rec. S.1503.
55 Letter from CNES to ARCEP regarding Starlink’s request for a radio frequency use authorization, Ref.
DS/DAI/D-2022-0006202 (May 9, 2022).
http://www.viasat.com 31
ITU-R Recommendation. S.1503-3 explains the necessity of complying with all EPFD limits at
all locations and for all geometries. Specifically:
The epfd limits in Article 22 are applicable for all GSO ESs and all pointing angles
towards that part of the GSO arc visible from that ES. [] It remains necessary for the
non-GSO operator to meet the epfd limits in Article 22 for all [] geometries including
the testing of specific GSO networks as noted in § A1.3.56
The Transfinite Visualyse EPFD software used in this analysis allows precisely that type of
evaluation called for by S.1503-3. It assesses the expected impact of the Starlink system for
a GSO ES located at Fuchsstadt, Germany (50.118°N. 9.924°E) with a GSO satellite located at
17.6°E longitude serving Germany.
This analysis uses (i) the constellations defined by SpaceX’s EPFD input files for the particular
ITU filings that it has specified as relevant (which data vary in some respects from the data
initially provided in ITU notifications), and (ii) the particular orbital deployment
configuration that SpaceX specified, all during the licensing process at the United States
Federal Communications Commission (FCC).
Notably, this analysis does not suggest that Starlink could not be operated in a manner
compliant with the ITU Radio Regulations.
This analysis shows that SpaceX does not plan to operate Starlink in a manner compliant
with the EPFD↓ limits in the ITU Radio Regulations.
To comply with those EPFD↓ limits, Starlink could employ various combinations of its own
choosing of (i) numbers of satellites, (ii) specific orbit parameters, (iii) power flux density
(PFD) emissions masks, (iv) effective isotropic radiated power (EIRP) emissions masks, (v)
GSO network avoidance angles, and (vi) frequency reuse parameters.
A-II. Analysis of EPFD↓ Violations by 4,408 Satellites in Starlink’s First Generation
Configuration
The following are examples of EPFD↓ exceedances for the first generation Starlink
configuration of 4,408 satellites, which, when tested only with the WCG combination of GSO
ES location and GSO satellite longitude, has received a favorable finding under the ITU’s
“spot check” process57 described above. By way of example, the WCG for the 10.7 GHz, 1.2
m, FSS limit is a GSO ES in the ocean approximately 200 km off the coast of West Africa with
a GSO satellite at about 1.5°E longitude.
This analysis is for a GSO ES located in Fuchsstadt, Germany (50.118°N. 9.924°E) with a Kuband GSO satellite located at 17.6°E longitude. The instances depicted below in which
EPFD↓ limits are violated 1%, 10%, and even 100% of the time are most concerning and

56 ITU-R Rec. S.1503-3, § D3.
57 319520108_STEAM-1_ResultsSummary.pdf (itu.int) and 319520109_STEAM-2B_ResultsSummary.pdf
(itu.int).
http://www.viasat.com 32
violate ITU Radio Regulations. Interference generated at those levels could well degrade
service levels and cause capacity losses to GSO networks.
The following figures show that the Starlink STEAM-1 and STEAM-2 filings exceed the Article
22 EPFD↓ limits in Tables 22-1A, 22-1B, and 22-1D in the Ku and Ka bands for a GSO ES
located in Fuchsstadt, Germany (50.118°N. 9.924°E) with a GSO satellite located at 17.6°E
longitude, even though it does not exceed the limits at the so-called WCG58. The peak
exceedances are shown in Table A-1. Combinations of other earth stations and satellite
locations serving Germany could result in larger violations of ITU limits than these examples.
Table A-1: Example peak STEAM-1 and STEAM-2 exceedances in Fuchsstadt,
Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
System Service Freq
Antenna
Diameter
Radiation
Pattern
Peak
Exceedance
Percent
of Time Figure
STEAM-1 FSS 10.7 GHz 1.2 S.1428 6.3 dB 0.50% A-1
STEAM-1 FSS 11.7 GHz 1.2 S.1428 5.5 dB 0.50% A-2
STEAM-1 BSS 11.7 GHz 0.45 BO.1443 5.3 dB 93.58% A-3
STEAM-1 BSS 11.7 GHz 0.6 BO.1443 4.1 dB 59.58% A-4
STEAM-1 FSS 12.2 GHz 1.2 S.1428 5.1 dB 0.50% A-5
STEAM-1 BSS 12.2 GHz 0.45 BO.1443 4.9 dB 91.48% A-6
STEAM-1 BSS 12.2 GHz 0.6 BO.1443 3.7 dB 59.58% A-7
STEAM-1 FSS 12.5 GHz 1.2 S.1428 4.8 dB 0.50% A-8
STEAM-1 BSS 12.5 GHz 0.45 BO.1443 4.7 dB 90.89% A-9
STEAM-1 BSS 12.5 GHz 0.6 BO.1443 3.5 dB 60.10% A-10
STEAM-2B FSS 17.8 GHz 1 S.1428 3.3 dB 10.00% A-11

58 The EPFD data underlying the WCG plots was generated with the ITU’s EPFD software using the STEAM
EPFD input databases available from the ITU at EPFD data and EPFD examination results (itu.int).
http://www.viasat.com 33 WCG (ES: 4.41°N, 2.78°E, GSO: 1.45°E) Fuchsstadt, Germany
Figure A-1: Comparison of STEAM-1 EPFD↓ at 10.7 GHz with 1.2 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 34 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-2: Comparison of STEAM-1 EPFD↓ at 11.7 GHz with 1.2 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 35 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-3: Comparison of STEAM-1 EPFD↓ at 11.7 GHz with 0.45 cm GSO ES for
WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 36 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-4: Comparison of STEAM-1 EPFD↓ at 11.7 GHz with 0.6 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 37 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-5: Comparison of STEAM-1 EPFD↓ at 12.2 GHz with 1.2 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO Satellite at 17.6°E
http://www.viasat.com 38 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-6: Comparison of STEAM-1 EPFD↓ at 12.2 GHz with 0.45 cm GSO ES for
WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO Satellite at 17.6°E
http://www.viasat.com 39 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-7: Comparison of STEAM-1 EPFD↓ at 12.2 GHz with 0.6 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 40 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-4: Comparison of STEAM-1 EPFD↓ at 12.5 GHz with 1.2 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 41 WCG (ES: 4.41°N, 2.79°E, GSO: 1.45°E) Fuchsstadt, Germany
Figure A-9: Comparison of STEAM-1 EPFD↓ at 12.5 GHz with 0.45 GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 42 WCG (ES: 4.41°N, 2.79°E, GSO: 1.45°E) Fuchsstadt, Germany
Figure A-10: Comparison of STEAM-1 EPFD↓ at 12.5 GHz with 0.6 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 43 WCG (ES: 4.41°N, 2.84°E, GSO: 1.50°E) Fuchsstadt, Germany
Figure A-11: Comparison of STEAM-2 EPFD↓ at 17.8 GHz with1 m GSO ES for WCG
and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
http://www.viasat.com 44
A-III. Analysis of EPFD↓ Violations by Additional 29,988 Satellites in Starlink’s Second
Generation Configuration
The following are examples of EPFD↓ exceedances for the additional 29,988 satellites in the
second generation Starlink configuration, which has not yet been evaluated by the ITU.
SpaceX proposes to operate those additional satellites under 18 different ITU filings.59 As
shown below, Starlink exceeds the Article 22 EPFD↓ limits in Table 22-1B for the 17.8 – 18.6
GHz band with several of these filings even when they are evaluated individually. Moreover,
when all 18 ITU filings are considered together, the EPFD↓ exceedances are substantially
greater.
This analysis is for a GSO ES located in Fuchsstadt, Germany (50.118°N. 9.924°E) with a Kaband GSO satellite located at 17.6°E longitude. The instances depicted below in which
EPFD↓ limits are expected to be violated 1%, 10%, and even 100% of the time are most
concerning and violate the ITU Radio Regulations. Interference generated at those levels
could well degrade service levels and cause capacity losses to GSO networks.
Notably, this analysis does not factor in the aggregate effect of the Starlink satellites
operated under ITU filings other than those listed in the footnote below, such as the 4,408
first generation satellites discussed above.
A. Starlink Second Generation EPFD↓ Exceedances under Individual ITU Filings
Table A-2 shows examples of EPFD↓ exceedances that exist for the second generation
Starlink configuration when the various 18 underlying ITU filings are examined in isolation.
Combinations of other earth stations and satellite locations serving Germany could result in
larger violations of ITU limits than these examples.
Table A-2: Example peak SpaceX Gen2 exceedances in Fuchsstadt, Germany
(50.118°N. 9.924°E) with GSO satellite at 17.6°E for the 17.8 – 18.6 GHz band with 1-
m GSO ES antenna diameter
System
Peak
Exceedance
Percent
of Time Figure
USASAT-NGSO-3V-2 3.2 dB 10% A-12
USASAT-NGSO-3W-1 3.2 dB 10% A-13
USASAT-NGSO-3W-2 3.2 dB 10% A-14

59 The relevant ITU system filings are: USASAT-NGSO-3N, USASATNGSO-3O, USASAT-NGSO-3P, USASATNGSO-3Q, USASAT-NGSO-3R1, USASATNGSO-3R2, USASAT-NGSO-3S1, USASAT-NGSO-3S2, USASAT-NGSO3S3, USASAT-NGSO-3T1, USASAT-NGSO-3T2, USASAT-NGSO-3T3, USASAT-NGSO-3U1, USASAT-NGSO-U2,
USASAT-NGSO-3V1, USASAT-NGSO-3V2, USASAT-NGSO-3W1, and USASAT-NGSO-3W2.
http://www.viasat.com 45
The following figures contrast these EPFD↓ violations in Germany with the WCG results. By
way of example, the WCG60 for the 17.8 GHz, 1.0 m, FSS limit, calculated for the USASATNGSO-3V-2 system, is a GSO ES in Tathlith Saudi Arabia with a GSO satellite located near 5°E
longitude.
As can be seen, the second generation Starlink configuration is clearly non-compliant with
the ITU Radio Regulations.

60 The EPFD data underlying the WCG plots was generated with the ITU’s EPFD software using the STEAM
EPFD input databases provided by SpaceX for each of the 18 Gen2 ITU filings.
http://www.viasat.com 46 WCG (ES: 12.23°N, 65.08°W, GSO: 112.54°W) Fuchsstadt, Germany
Figure A-12: Comparison of USASAT-NGSO-3V-2 EPFD↓ in 17.8 – 18.6 GHz Band with
1-m GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO
satellite at 17.6°E
http://www.viasat.com 47 WCG (ES: 6.59°N, 93.77°W, GSO: 98.84°W) Fuchsstadt, Germany
Figure A-13: Comparison of USASAT-NGSO-3W-1 EPFD↓ in 17.8 – 18.6 GHz Band with
1-m GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO
satellite at 17.6°E
http://www.viasat.com 48 WCG (ES: 6.59°N, 80.89°W, GSO: 85.95°W) Fuchsstadt, Germany
Figure A-14: Comparison of USASAT-NGSO-3W-2 EPFD↓ in 17.8 – 18.6 GHz Band with
1-m GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO
satellite at 17.6°E
http://www.viasat.com 49
B. Starlink Second Generation EPFD↓ Exceedances under Combined ITU Filings
This section evaluates the interference levels that would be generated by the additional
29,988 second generation Starlink satellites operating under SpaceX’s 18 new ITU filings—
and compares those interference levels to applicable ITU Article 22 single-entry EPFD↓ limits
and ITU Resolution 76 aggregate EPFD↓ limits. Notably, SpaceX has made clear that its
29,988 additional satellites would operate as a single non-GSO system.61
Combined EPFD↓ curves were generated for all 29,988 satellites operating under these 18
filings with a 1-m GSO ES in the 17.8 – 18.6 GHz band, using the EPFD input files provided by
SpaceX for each of those 18 ITU filings. The GSO ES is located in Fuchsstadt, Germany
(50.118°N. 9.924°E) with the GSO satellite at 17.6°E longitude. The resulting 18 EPFD↓
probability density functions (pdf’s) for each of the cases identified in the Article 22 and
Resolution 76 EPFD↓ limits were combined, using standard techniques for the sum of
independent random variables,62 to generate the combined EPFD↓ cdf curves.
Figure A-15 shows the results of this analysis and depicts: (i) the Article 22 single-entry limit
cdf curve; (ii) the Resolution 76 aggregate limit cdf curve; and (iii) the combined EPFD cdf
curve for 29,988 Starlink satellites generated using the methodology described above. The
analysis shows that Starlink would exceed both the Article 22 single-entry limits and the
Resolution 76 aggregate limits for all percentages of time and all EPFD levels. The peak
exceedances are 9.4 dB above the Article 22 limit and 4.0 dB above the Resolution 76
limit, each at 10% of the time.63

61 See, e.g., Consolidated Opposition to Petitions and Response to Comments of Space Exploration Holdings,
U.S. Federal Communications Commission IBFS File Nos. SAT-LOA-20200526-00055 and SAT-AMD20210818- 00105, at 3, (confirming that SpaceX intends to operate a single “Gen2 system”).
62 The relevant techniques used are discussed in most textbooks on probability theory. See, e.g., Marco
Taboga, Sums of independent random variables, STATLECT, available at
https://www.statlect.com/fundamentals-of-probability/sums-of-independent-random-variables (last
visited Aug. 24, 2022); Alex Tsun, Convolution, available at
https://courses.cs.washington.edu/courses/cse312/20su/files/student_drive/5.5.pdf (last visited Aug. 24,
2022).
63 Does not factor in the aggregate effect of the 4,408 first generation satellites discussed above.
http://www.viasat.com 50
Figure A-15: Combined EPFD↓ for 29,988 Gen2 Starlink satellites in 17.8 – 18.6 GHz
band with 1-m GSO ES for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO
satellite at 17.6°E
Again, ITU-R Recommendation S.1503 is instructive. It is based on the premise that the
parameters specified in relevant EPFD input files reflect the way that a non-GSO system
would actually operate once implemented. Among other things, the methodology is based
on all satellites that could contribute to the EPFD levels generated by the entire system being
considered together. Thus, for example, that Recommendation explicitly anticipates that
where a large constellation is divisible into separate “sub-constellations,” EPFD compliance
will still be evaluated across the constellation as a whole.
64

64 ITU-R Rec. S.1503-3, § A2.4 (specifying constellation types that can be evaluated using specified
procedures and explicitly noting that “[c]onstellations can contain sub-constellations with different orbit
parameters and shape . . .”).
http://www.viasat.com 51
A-IV. STEAM-1 ID Number 121520025 Exceedance
BR International Frequency Information Circular (Space Services) (BR IFIC) Number 2981 (4
October 2022) promulgated a “favorable” finding for STEAM-1 ID 121520025. This modified
version of the STEAM-1 notice corresponds to the current 4,408 satellite configuration in
four shells (540 km, 550 km, 560 km, and 570 km).
As with the prior STEAM-1 favorable finding (ID 114520273), reported upon above, even
though this new filing received a favorable finding from the BR it exceeds the Art. 22 EPFD↓
limits in Tables 22-1A and 22-1D for a GSO ES located in Fuchsstadt, Germany (50.118°N.
9.924°E) with a GSO satellite located at 17.6°E longitude65. Exemplary peak exceedances are
shown in Table A-3. Combinations of other earth stations and satellite locations serving
Germany could result in larger violations of ITU limits than these examples.
Table A-1: Example peak STEAM-1 (ID 121520025) exceedances in Fuchsstadt,
Germany (50.118°N. 9.924°E) with GSO satellite at 17.6°E
System Service Freq
Antenna
Diameter
Radiation
Pattern
Peak
Exceedance
Percent
of Time Figure
STEAM-1 FSS 10.7 GHz 1.2 m S.1428 0.6 dB 0.79% A-16
STEAM-1 BSS 12.7 GHz 0.45 m BO.1443 4.2 dB 89.75% A-17
STEAM-1 BSS 12.7 GHz 0.6 m BO.1443 3.1 dB 71.6% A-18

65 The EPFD data underlying the WCG plots was generated with the ITU’s EPFD software using the STEAM
EPFD input databases available from the ITU at EPFD data and EPFD examination results (itu.int).
http://www.viasat.com 52 WCG (ES: 6.59°N, 93.77°W, GSO: 98.84°W) Fuchsstadt, Germany
Figure A-16: Comparison of STEAM-1 (ID 121520025) EPFD↓ at 10.7 GHz with 1.2 m
GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite
at 17.6°E
http://www.viasat.com 53 WCG (ES: 6.59°N, 93.77°W, GSO: 98.84°W) Fuchsstadt, Germany
Figure A-17: Comparison of STEAM-1 (ID 121520025) EPFD↓ at 12.7 GHz with 0.45 m
GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite
at 17.6°E
http://www.viasat.com 54 WCG (ES: 6.59°N, 93.77°W, GSO: 98.84°W) Fuchsstadt, Germany
Figure A-18: Comparison of STEAM-1 (ID 121520025) EPFD↓ at 12.7 GHz with 0.6 m
GSO ES for WCG and for Fuchsstadt, Germany (50.118°N. 9.924°E) with GSO satellite
at 17.6°E
ANNEX B:
Hindering Equitable Access to NGSO Frequency Bands
http://www.viasat.com 56
Annex B: Hindering Equitable Access to NGSO Frequency Bands
The adverse effect of large NGSO systems on smaller NGSO systems is illustrated by Table B1 below, which shows the probability that a NGSO system of one size blocks another NGSO
system of a different size. Representative NGSO systems were modelled with 100, 300,
1,000, 3,000, and 10,000 satellites. The probability of blocking (the system being blocked
not being able to find one of its satellites with sufficient angular separation from a satellite
of the blocking system to avoid interference) was computed by Monte Carlo simulation.
The percentages reflect the amount of time near in-line interference events can be
expected.
Blocking System Number of Satellites
300 1,000 3,000 10,000 30,000
Blocked System Satellites
300 – 9.4% 36.3% 96.9% 100.0%
1,000 0.0% – 9.5% 92.4% 100.0%
3,000 0.0% 0.0% – 89.0% 100.0%
10,000 0.0% 0.0% 0.0% – 100.0%
30,000 0.0% 0.0% 0.0% 50.7% –
Table B-1: Percentage of Time Large NGSO System Hinders Smaller NGSO Systems
As reflected in Table B-1, the larger constellations would have a significant impact on
smaller NGSO systems with the smaller systems experiencing blocking virtually all of the
time. The adverse impact of the large system can also be illustrated by examining the “look
angles” that would be blocked as a function of NGSO constellation size. Figure B-1 below
depicts the percentage of available look angles that would be consumed by the NGSO
systems as a function of the number of satellites they incorporate. As Figure B-1 shows, a
10,000-satellite NGSO constellation would block about 79 percent of the look angles
available from an earth station location, and a 30,000 satellite NGSO constellation would
block virtually all of the look angles available from that same location.
http://www.viasat.com 57
Figure B-1: Percent of Look Angles Used as a Function of NGSO Constellation Size
Large NGSO constellation’s ability to “block” smaller NGSO systems would effectively reduce
the capacity available to those smaller systems.
Critically, the large NGSO system itself would never be “blocked,” or suffer any reduction in
available capacity, as a result of the operation of smaller NGSO systems. This is because it
would be able to leverage the satellite diversity afforded by the extremely large number of
satellites in the system; in the event of an in-line interference event involving one satellite,
it could simply reroute through another of its satellite.

Notably, and as discussed in Section 1.B above, one solution would be to adopt a license
condition requiring “look angle” splitting, whereby NGSO systems serving the country in
overlapping frequencies would divide the range of satellite azimuths as seen from a location
on the Earth whenever the potential for interference exists at that location. For example,
on such occasions one system would only operate with satellites to the West of that
location while the other system would only operate with satellites to the East of that
location. As long as each system has a satellite available in its assigned direction that is not
within the minimum avoidance angle of a satellite in the other system, there would be no
capacity reduction. The same level of “look angle” splitting would occur regardless of the
number of satellites in a given NGSO constellation. Each operator would bear the same
burden by default, in the absence of some other coordinated outcome. This approach
would allow multiple NGSO systems to access and use available spectrum resources on an
equitable basis.

Fully uninstall HTC Sync Manager on OSX

Perhaps you want to stop HTC sync manager launching at startup, or want to fully delete the app.

It took me a few minutes to figure this one out, so I thought I would share the love to save people time in the future.

Stop HTC sync manager launching at startup

1. In finder click “Go”->”Go to Folder”
2. Type “~/Library/LaunchAgents”
3. Click Go
4. Delete the file named “com.nero.HSMMonitor.plist”
5. Alternatively, you could try typing the following command in a terminal window: “launchctl unload -w ~/Library/LaunchAgents/com.nero.HSMMonitor.plist” – However this is hit and miss whether it will work or not

Uninstall the app

1. Simply drag the application from the applications folder to the trash!
2. If you get an error saying the app is running, click the icon on the top right and choose “Quit”
3. If you still get an error, open Activity Monitor, select the HTC Sync Manager app and choose “Force Quit”
4. Once the application has quit, drag it to the trash

Hope this helps. Feel free to share your experience in the comments box.

An Introduction to Deep Space Communication

While working on an MSc program, I chose Deep Space Communication as an area to research. I knew nothing about the subject beforehand, but found it fascinating. A few friends and family expressed an interest in the area and I thought it may be worthwhile distilling some of the basics into a single introductory document. It is not so easy to find an easy to digest introduction on this subject, as many documents are pretty full on! So hopefully this will be useful to those interested in how we manage to communicate with spacecraft billions of Km from earth.

Please feel free to share and comment. If you have anything you would like to discuss or any specific questions you think I may be able to answer, please get in touch by commenting or via LinkedIn.

Abstract This paper is aimed at readers with an interest in deep space communication, but do not have any prior knowledge. The content can be used to gain a basic understanding to satisfy a passing interest, and also provide a foundation for further learning as required. Topics covered: Unique challenges of deep space communication, international deep space networks, radio frequency communication fundamentals and deep space antenna design.

Link to Document: An Introduction to Deep Space Communication

Interesting Enterprise Architecture Analogy using Tetris

To people who’ve not yet come across enterprise architecture, this graphic may be useful to give a very high level appreciation of the different pieces of the EA puzzle.

Fixing corrupt Plex thumbnails

Plex is nothing short of fantastic!
It really brings TV and Movie collections to life and makes browsing and watching media so much better than any other system I have ever used.

I did however find a problem the other day, where the thumbnails for some movies were corrupt. For example, if you imagine the image is downloaded from the top down, only half the image is showing and the rest is just grey.

At the time of writing this article, there are no other fixes published online, other than deleting your entire Plex metadata! So if you  have this problem and want a reasonably quick fix, read on…..

This fix finds the location of the Plex metadata for the movie with the corrupt thumbnail, then simply removes it and forces Plex to download a new copy of the metadata. It is fairly straightforward, but a little tricky, so please read each step carefully and use copy and past on the provided commands to avoid typos.

This fix will also work for other content such as TV shows etc with a few very obvious tweeks.

1. Open up a terminal and run this command to change to the Plex DB directory (Notice the backslashes escaping the spaces in the directory names):

cd ~/Library/Application\ Support/Plex\ Media\ Server/Plug-in\ Support/Databases

2. Connect to the Plex DB with sqlite by running this command in the terminal window:

sqlite3 com.plexapp.plugins.library.db

You will see something like this:
iMac:Databases nik$ sqlite3 com.plexapp.plugins.library.db
SQLite version 3.6.12Enter ".help" for instructions
Enter SQL statements terminated with a ";"
sqlite>

3. Type this SQL query into the terminal window to find the GUID of the movie, this will help us find the movie metadata location:

Obviously replace ‘your movie name here’ with the movie you want to fix.

select title, guid from metadata_items where title like '%your movie name here%';

For example:

sqlite> select title, guid from metadata_items where title like '%school of rock%';

You should see the movie name and the guid, separated by a pipe (|)

My result:

The School of Rock|com.plexapp.agents.imdb://tt0332379?lang=en


4. Find the location (folder and bundle name) of the movie metadata. Close down the previous terminal window and run this command in the new window:

Obviously replacing everything in between the quotes with the guid you go when you ran your SQL query.

echo -n "com.plexapp.agents.imdb://tt0332379?lang=en" | shasum

This command will return a big long string, like this:

d616f6685a11c774befb391dc13b7c0558908acf

Which actually contains a folder name (The first character) and the name of the bundle file (The remaining characters).

Your string will be different, but the format is the same as the following:

(d) (616f6685a11c774befb391dc13b7c0558908acf)

Foldername: d
Bundle Name: 616f6685a11c774befb391dc13b7c0558908acf

5. Find the directory holding the Plex movie metadata:

In finder browse to the following directory:

~/Library/Application Support/Plex Media Server/Metadata/Movies

You will notice lots of directories named 0,1,2,3a,b,c etc.

Take the directory name (1st letter of the sha checksum) from step 4 and open that directory.

In my case this was the directory named “d”. Then find the bundle name in the folder, in my case this was “616f6685a11c774befb391dc13b7c0558908acf.bundle”

6. Move the bundle file found in step 5 to a temporary location, your desktop for example

7. Now we need to tell Plex to overwrite the cached metadata:

a) Open Plex Media Manager (Click the Plex icon at the top of the screen, then click Media Manager)

b) Find the Movie with the partially downloaded artwork, right click and choose ‘Fix Incorrect Match’

c) All you need to do in this step is select a different movie, it doesn’t matter what it is , as long as it is different. Also, make sure you remember what the correct match was!

Plex will now download the metadata for the dummy match we have just given it. Watch in Plex Media Manager for this to update.

8. Tell Plex to download the correct metadata for the Movie:

a) Find the Movie with the partially downloaded artwork in Media Manager,  right click and choose ‘Fix Incorrect Match’ again

c) Now select the correct movie, Plex will now re-download the correct metadata, including a new copy of the artwork! Replacing your corrupt thumbnail 🙂

A huge thanks to SolarPlex on the Plex forums for this article, which helped me connect to the Plex DB and find the correct metadata folder for the movie.

Here’s a link to the SolarPlex article:

http://forums2.plexapp.com/index.php/topic/31636-howto-query-data-from-plex-on-a-mac/

How to find your WordPress API key

I have just spent a long time trying to find my wordpress API key.

Your API key is used to link web applications to your WordPress blog, such as SiteStats or YouTube.

Almost every web tutorial says it’s on your profile page once you have logged into wordpress, however I think our friends at wordpress.com may have moved it recently and not yet updated their documentation.

So if you are looking for your wordpress API key (Assuming you already have an account), simply go to https://apikey.wordpress.com, log in and you will find your API key on the site.

Hopefully this will save you wasting your time digging through help files and web tutorials 🙂

Share your Aperture Images with Everyone, Everywhere!

If you want to share your Aperture images with anyone, using any device, anywhere in the world and never worry about losing your images, read on!

Like many people I have more than one type of device connected to my home network. For me it’s a Mac, a couple of Windows laptops, a Windows media server, an Xbox and a PS3.

This tutorial will guide you through the steps needed to share your Aperture albums on your home network as well as with your friends and family over the internet quickly and easily.

Assuming you already have everything in your home connected to your home network, let’s get started….

The Solution

First the images are exported from Aperture onto a Media Server. The Media Server is then used to share the images to everything else.

I personally prefer to have a separate Media Server, however this solution could also be implemented without a separate media server, by exporting images and installing all software directly onto the Mac.

Take a look at the image below which shows the overall solution.

Exporting the Images from Aperture

Images are exported from Aperture using a custom Aperture Export utility, this can be run everytime you create a new project to ensure that all your shared images are up to date. This is described in a later section of this article.

Sharing the Images with the PS3 and Xbox

Both the PS3 and the Xbox support an open protocol named DLNA (www.dlna.org). This has become the standard way to share and play media around the home. If you look for it you will see the DLNA logo on more devices than you think, including stereo systems, TVs, media software and NAS devices.

For more info including a full list of products certified to work with DLNA click the DLNA link above. DLNA also supports the streaming of movies and music to all compatible devices around your home, so after sharing your images around your network, why not share your other media too!

To share the images with a PS3/Xbox or any other DLNA compatible device I recommend Twonky Media Server (http://www.twonky.com/products/twonkyserver/) its $19.95 and worth every penny/cent whatever….

You simply install the software on your media server (Windows, Mac or Linux) and configure it to share out your files. The configuration is so simple it doesn’t warrant a step by step tutorial.

Twonky is excellent and I strongly recommend it, however feel free to check out the alternatives below.

• TVersity (http://tversity.com) – Windows Only, lots of functionality, however can be unreliable when streaming some HD movies
• Windows Media Player 11+ – Free
• PlayOn (http://www.playon.tv) – Comprehensic + supports many Internet TV channels too
• MediaLink (http://www.nullriver.com/products/medialink) – Mac Only. Simple + stable
• Playback (http://www.yazsoft.com/) – Mac Only. Good functionality + simple to use

Getting the Images onto the Cloud

“Cloud” is used generally to refer to a service someone else manages which you consume over a network, you don’t need to know how the company does what they do, simply how to use their service.

For this tutorial, our cloud is an internet based backup service that we copy all the Aperture images to.

This means two very important things:

• All the images are backed up to the internet service. So if anything ever happened like a cooked hard drive, or fire etc all the treasured images are safe
• The images can be accessed over the Internet from anywhere in the world

To get the images into the cloud you simply install a client and configure which folders you want to sync. It can take a while though depending on how many files you have and the speed of your internet connection! Once sync’d though it will stay in sync, so whenever you place any new files onto the media server, they will automatically be copied to the cloud.

I strongly recommend SafeSync from Trend Micro. They have an offer on at the moment which allows unlimited storage for a really low price. The client software and website are not the prettiest or easiest to use but the value for money in incredible compared to other similar providers.

SafeSync is available here: https://www.safesync.com/Pages/Welcome however you may want to check out these other providers depending on how many files you have:

• Dropbox (www.dropbox.com) Free 2GB account here: http://db.tt/C55ZmIw – Excellent & rock solid. Mac + Windows, single sync folder location
• SugarSync (www.sugarsync.com) Free 5GB account here: https://www.sugarsync.com/referral?rf=dtqa9if9wrpcd Excellent, rock solid and a pleasure to use. Mac + Windows, multiple sync folder locations

Aperture Export Utility

I created this export utility using AppleScript which you can download using the link below.

Rather than publish this as compiled code, I chose to publish the source code for all the budding applescripters:

-- --------------------------------
-- ExportAllProjects_V2.scpt
-- --------------------------------

-- ------------------------------------
-- Nik Ansell (nikansell00@gmail.com)
-- March 2011
-- ------------------------------------

-- ------------------------------------------------
-- Purpose:
-- Exports all images in the Aperture DB in all projects to any folder
-- ------------------------------------------------

-- ---------------------------
-- Pre-Requisites:
-- ---------------------------

-- 1. Ensure that a folder naming policy exists named "Project Name"
-- 2. Ensure you understand what the script is doing before you run it. I will not be held accountable for any issues as a result of running this script!

-- ---------------------------
-- Features:
-- ---------------------------

-- 1. Prompts for the destination folder
-- 1.1 This can be changed by simply uncommenting the section in the script below
-- 2. Promnpt for the folder naming policy, "Project Name" is required for other features to work, please create if does not exist already
-- 2.1 This can be changed by simply uncommenting the section in the script below
-- 3. Exports all images as full size JPEGs
-- 3.1 This can be changed by changing the file naming policy section in the script below
-- 4. Sub folders are created using the image year of the first image in the project (Because "Image Year"in the Dir Naming Policy does not always work)
-- 5. Bypasses Aperture timeout errors
-- 6. Checks if the destination folder exists, if it does exist it skips if the number of images in the folder are the same as the number of images in the project
-- 6.1 Can be set to delate all images in the destination folder before exporting if needed (By choosing "Yes" when prompted
-- 7. Writes all events to a logfile at path: Desktop/Aperture_.txt
-- 8. Logs the total images found, images skipped and images exported
-- 9. Uses the original image name when exporting
-- 10. The export dir can be a network path if mounted before the script starts

-- ---------------------------
-- Known Bugs:
-- ---------------------------

-- 1. Sometimes Aperture does not return all projects, causing some projects to be skipped. This may e related to Known Bug No.2
-- Workaround: Run the script more than once, selecting "No" when prompted: "Delete files from destination folder before exporting?"

-- 2. If more than one project has the same name, all files from all projects of the same name will be placed in the same folder, or the next iteration of the project will be skipped
-- Workaround: Ensure that every project has a unique name. If you find image counts in the summary do not match the destination folders this could be your problem

-- 3. If Aperture is not able to export a file, this breaks feature 6 as the number of images will be less when exported
-- Workaround: Fix the problem and ensure that Aperture can export all images. Try exporting a project manually to test, then work through any issues you find

-- 4. If an image has no date in Aperture it may not be exported
-- Workaround: Find images without a date and choose Metadate->Adjust Date/Time, then restart Aperture

set {year:y, month:m, day:d} to (current date)
global logfilePath
set logfilePath to (path to desktop as string) & "ApertureExport_" & d & m & y & ".txt"
display dialog "Using Logfile:" & logfilePath

-- Get the path to export the files to
tell application "Finder"
set export_dir to (choose folder with prompt "Choose a folder to export into") as alias
end tell

tell application "Aperture"
activate

-- Selecting "Yes" will delete all images in a destination folder, if a destination folder already exists
set question to display dialog "Delete files from destination folder before exporting?" buttons {"Yes", "No"} default button 2
set DeleteFilesBeforeExport to button returned of question

-- Name exported files the same as the name stored in Aperture
-- Change the section below if you'd like a prompt the file naming policy
set file_policy to file naming policy "Version Name"
--set x to name of file naming policies
--choose from list x with prompt "select a file naming policy"
--set file_policy to file naming policy (item 1 of result)

-- Prompt for the folder naming policy to use
-- Change the section below to stop prompt and hard code "Project Name"
--set dir_policy to folder naming policy "Project Name"
set x to name of folder naming policies
choose from list x with prompt "Select a folder naming policy"
set dir_policy to folder naming policy (item 1 of result)

-- Export all images as Full size JPEGs
-- Change the section below to remove the prompt and hard code "Project Name"
set setting_name to "JPEG - Original Size"
--set export_setting to name of export settings
--set end of export_setting to "Master"
--choose from list export_setting with prompt "Choose a file type preset"
--set setting_name to item 1 of result

-- Initialize the log file
my WriteToLog(((current date) as string) & return, "yes")
my WriteToLog("Starting export of all Aperture images using the variables below:" & return, "no")
my WriteToLog(" export_dir: " & export_dir as string, "no")
my WriteToLog(" file_policy: Version Name", "no")
my WriteToLog(" dir_policy: Project Name", "no")
my WriteToLog(" setting_name: " & setting_name as string, "no")
my WriteToLog(" DeleteFilesBeforeExport: " & DeleteFilesBeforeExport as string, "no")
my WriteToLog(return, "no")

-- Set some vars to report the results at the end
set totalimages to 0
set totalimagesskipped to 0
set totalimagesexported to 0
set totalprojects to 0

-- Get all projects and cycle through them
set theplist to name of every project
set totalprojects to count theplist

repeat with p in theplist

set pobj to project p
set skip to "no"

tell pobj
set theimages to every image version as list
end tell

set numImagesinProject to count theimages

my WriteToLog("Found Project: " & p & " - " & numImagesinProject & " images", "no")

set totalimages to totalimages + numImagesinProject

if (numImagesinProject > 0) then

-- Get the year of the 1st image in the project
set sampleimage to item 1 of theimages
set sampleimagename to name of sampleimage
try
set sampleimageyear to value of EXIF tag "CaptureYear" of sampleimage as string
on error number -1700
set sampleimageyear to "0000"
end try
set sampleimageyear to rich text 1 thru 4 of sampleimageyear
set p to p as string
set sampleimageyear to sampleimageyear as string

-- Create the "year" folder if it doesn't exist
tell application "Finder"
if not (exists folder sampleimageyear of export_dir) then
my WriteToLog((" Creating folder: " & export_dir & sampleimageyear), "no")
make new folder at export_dir with properties {name:sampleimageyear}

end if -- if year sub folder does not exist

end tell -- tell application finder

-- Define the export dir in which to place the project folder
-- This is done to avoid two different export locations if a project spans over more than one year (E.G xmas and new year)
set export_subdir to (export_dir as string) & sampleimageyear as alias

-- Set the variable to print to log and check total exported files
set chk_dir to export_subdir & p as string

-- If folder exists, check number of images before exporting
tell application "Finder"
if (exists folder chk_dir) then
my WriteToLog(" Destination folder exists (" & chk_dir & "), counting images", "no")
-- Count images in folder
set chk_dir to chk_dir as alias
set numFilesinFolder to count of (files in folder chk_dir)
set strnumFilesinFolder to numFilesinFolder as string

if (numFilesinFolder ≥ numImagesinProject) then
set totalimagesskipped to totalimagesskipped + numImagesinProject
my WriteToLog(" Found " & strnumFilesinFolder & " files in destination folder skipping", "no")
set skip to "yes"
else
if DeleteFilesBeforeExport is "Yes" then
my WriteToLog(" Found " & strnumFilesinFolder & " Deleting files in folder before export to avoid duplicates", "no")
delete (every item of folder export_subdir)
end if -- if set to delete files in destination folder before exporting

end if -- if destination folder has more files than the project

end if -- if chk_dir exists

end tell -- tell application finder

if (skip is not equal to "yes") then
my WriteToLog((" Exporting: " & p), "no")
my WriteToLog(" To Folder: " & chk_dir, "no")
set totalimagesexported to totalimagesexported + numImagesinProject

if setting_name is "Master" then
with timeout of 3600 seconds
try
--export theimages naming files with file_policy naming folders with dir_policy to export_subdir metadata sidecar
export theimages naming files with file_policy naming folders with dir_policy to export_subdir metadata sidecar
--new to 2.0 is the ability to embed the versions' IPTC data into the master itself. change "sidecar" to "embedded" to do so.
on error number -1712 -- Timeout waiting for a confirmation message in Aperture
my WriteToLog(" Error: Timeout (Error -1712), waiting for a confirmation in Aperture, probably some images couldn't be exported", "no")
end try
end timeout
else
with timeout of 3600 seconds
try
export theimages naming folders with dir_policy using export setting setting_name to export_subdir naming files with file_policy
on error number -1712 -- Timeout waiting for a confirmation message in Aperture
my WriteToLog(" Error: Timeout (Error -1712), waiting for a confirmation in Aperture, probably some images couldn't be exported", "no")
end try
end timeout
end if -- if setting_name is "Master"

-- Check the right number of images were exported
tell application "Finder"
if (exists folder chk_dir) then
set chk_dir to chk_dir as alias
tell application "Finder"
set numFilesinFolder to count of (files in folder chk_dir)
end tell -- tell application finder
set strnumFilesinFolder to numFilesinFolder as string
my WriteToLog(" " & strnumFilesinFolder & " files found in destination folder, assuming all files exported successfully", "no")
if (numFilesinFolder < numImagesinProject) then
set diff to numImagesinProject - numFilesinFolder
set totalimagesskipped to totalimagesskipped + diff
set totalimagesexported to totalimagesexported - diff
my WriteToLog(" Error:Less files found in destination folder, try exporting manually in Aperture to troubleshoot", "no")
end if -- If less files in export folder than in project
else
-- Something went wrong with the export
my WriteToLog(" Error: Could not find destination folder, something went wrong with the export, check for previous errors", "no")
end if -- if chk_dir exists
end tell -- tell application Finder

end if -- if skip not equal to yes

end if -- if more than 0 files in project

end repeat -- repeat with every project

my WriteToLog(return & "Finished", "no")
my WriteToLog(((current date) as string) & return, "no")
my WriteToLog("Total Projects Found:" & totalprojects & return & "Total Images Found:" & totalimages & return & "Total Images Skipped:" & totalimagesskipped & return & "Total Images Exported:" & totalimagesexported, "no")
--display dialog "Total Projects Found:" & totalprojects & return & "Total Images Found:" & totalimages & return & "Total Images Skipped:" & totalimagesskipped & return & "Total Images Exported:" & totalimagesexported

end tell -- tell application Aperture

on WriteToLog(text2write, init)

set AppleScript's text item delimiters to ""

try
set fileRef to open for access logfilePath with write permission
try
if (init is "yes") then
-- Clear file contents
set eof of fileRef to 0
write text2write & return to fileRef
else
write text2write & return to fileRef starting at eof
end if -- if init value set to "yes"
end try
close access fileRef
end try
end WriteToLog

Feel free to use or modify the script in any way you choose.

However run the script at your own risk. Please do not run it unless you are comfortable with what it does! J

A few things you may want to know about this script are in the following sections.

What it does

1.     Extracts all Aperture images in your library to a folder of your choice. This can be a local or remote folder, as long as the folder is visible in the Finder application

2.     The following options are used when exporting:

Export Folder Format: <ExportFolder>/Year/ProjectName/

Export Image Format: JPEG – Original Size

3.     Additional Features:

a) Aperture timeout errors are bypassed

b) Skips the exporting of a project if the destination folder already exists, this allows the script to be re-run at any time and it will only export new projects. If you wish to override this feature select “Yes” when asked by the script.

c) Writes progress to a log file <Desktop>/Aperture_<date>.txt

How to use the export script

1.     Copy and paste the source code above into the Applescript editor and click “Compile”

2.     Read through the script and make sure you are happy with what it is doing

3.     Save the scpt file using the “Save As” in Applescript editor to any path you will remember

4.     Run the script by clicking “Run” in the Applescript editor

5.     The script will diaplay a message box with the path to the log file. Open this log file in the Apple logfile viewer as this will automatically update as the script logs it’s actions

6.     You will then be prompted for a path to export your images, make sure this path points to a location on your media server if you are using a media server to do the rest of the sharing. If not choose a location on you Mac

7.     Once the path is selected you wil be prompted to chose if you wish to delete files from the destination folder before exporting. Choose “No” if you want to only export new images

8.     You are now prompted with to choose a folder naming policy, select “Project Name”, if this doesn’t exist create one in Aperture by selecting any image, clicking “Export” then next to “Sub Folder Format” click “Edit” then click “+” to create a new folder naming policy

9.     The script will now export all the images to the chosen location, you can track the progress by opening the log file with any log file viewer

Known Bugs

• If more than one project has the same name, all files from all projects of the same name will be placed in the same folder, or the next iteration of the project will be skipped
• – Workaround: Ensure that every project has a unique name. If you find image counts in the log file summary do not match the destination folders this could be your problem

• For many reasons Aperture may not be able to export an image. If you see errors in the log file, try to export the project manually then work through any issues as they arise
• If an image has no date in Aperture it may not be exported
• – Workaround: Find images without a date and choose Metadate->Adjust Date/Time, add the correct data then restart Aperture and kick off the script again

Please let me know how you get on by leaving a comment below.

Thanks for reading.

Reduce your speeding and traffic fines in the UAE

Driving in the UAE is hard enough, but to make matters worse there are speed cameras everywhere!

EggOnFace.com has been setup to help you manage and reduce your speeding and traffic fines in the UAE by keeping you informed whever you get a fine.

Register on the site for free and get the following benefits:

• Receive an email automatically whenever you receive a new fine
• Check for any fines relating to multiple vehicles by simply entering a username and password (You no longer have to remember your vehicle details to check)
• Receive an email each month reminding you of any outstanding fines

The site is completely free and makes your life so much easier, visit www.EggOnFace.com and register to get started.

Watching UK TV on your PS3 from outside the UK

After living outside the UK for a while now, I have come to appreciate that UK TV is actually quite good and I miss it.

While some UK TV channels are available over the internet, if you are outside the UK, access to the sites is blocked.

This tutorial shows how to gain access to the UK TV sites from outside the UK using a PC/Mac. It also shows how to get the UK TV sites to work on a PS3.

Tutorial Steps

1. Configuring the network
2. Setting up a UK VPN
3. Setting up the proxy server
4. Configuring the PS3

Required

• A PS3 (UK Version with the iPlayer, 4OD and ITV Player icons installed)
• A PC/Mac
• An Internet Connection
• Some basic networking and PC/Mac skills

 

1. Configuring the Network

A static LAN IP Address is required on the PC/Mac, because if a DHCP server ever assigns a different IP Address to the PC/Mac you would need to change the PS3 configuration.
If you are certain the PC/Mac has a static IP Address already, get the IP Address and Subnet Mast and move onto the next section, if not complete the steps below.

1. Configure a static LAN IP Address on your PC/Mac
2. Ensure the Address you assign is excluded from the range of IP Addresses used by your DHCP server (Normally running on your router/modem
3. Make a note of your IP Address and Subnet Mask

 

2. Setting up a UK VPN

First a quick lesson on how networks and more specifically the internet works.

Everything (Computer, Webserver, Games Console, Internet Enabled Toaster etc) has a unique IP Address on the internet just like your home network.

A central authority allocates all IP Addresses and registers the location of the IP Addresses as they are allocated.

UK TV websites determine your location by looking at your IP Address when connecting to it, if the IP Address connecting to the TV website is not registered in the UK, access is blocked.

A UK VPN service tricks the UK TV website into thinking you are in the UK by making the connection to the UK TV website on your behalf, then sending the TV channel stream back to your PC/Mac.

Implementation

1. Subscribe to a UK VPN service. This will cost a small amount each month however it is 100% worth paying for as the free ones can be very unreliable. A great VPN service is http://www.Overplay.net however you can compare a number of UK VPN services using a site like http://www.vpnreviews.com
2. Configure the VPN. Each VPN service supplies its own configuration, so simply follow the instructions provided by the website. This tutorial assumes overplay.net was chosen and the Overplay VPN client was installed, however if you use another provider simply follow any VPN configuration steps provided by VPN service
3. Open the Overplay VPN client (Shown Below), Select one of the UK sites from the drop down list and click “Connect”, entering the correct username and password when prompted
4. OK so step 1 is complete. You now have access to UK TV websites on your PC/Mac. To test simply open your web browser and browse to the site of your choice E.G BBC iPlayer/ITV Player

 

3. Setting up the Proxy Server

A VPN cannot be configured on a PS3, so instead we need to connect to the internet via the PC/Mac with the UK VPN connection.

This is done by installing proxy server software on your PC/Mac, the proxy software simply connects to internet services on your behalf and sends you back all data it receives.

You will need to determine the network address from the IP Address from the previous step. Assuming your subnet mask is 255.255.255.0 (/24) if your IP A

ddress is 192.168.0.x, your network address is 192.168.0.0/24. If you IP Address is 192.168.1.x, your network address is 192.168.1.0/24.

Implementation

1. Download and install proxy server software onto your PC/Mac. The best one available for a Mac is “Squidman” (http://web.me.com/adg/squidman/index.html) which is simply a management utility for the great open source proxy “squid”. A good one for a PC is “ccproxy” (http://www.youngzsoft.net/ccproxy)
2. Configure the Proxy.This tutorial will assume the use of Squidman on a Mac, however the configuration for ccproxy is almost the same. There are two configurations required, clients and port, leave everything else unless you really know what you are doing.
3. Clients: (Shown Below) Open Squidman, install squid when prompted then open preferences. Click Clients, then enter the network address E.G. 192.168.0.0/24
4. Ports: (Shown Below) In the Squidman preferences panel click general and make a note of the port number. The default is 3128
5. Start Squid. To allow the proxy to start receiving connections from devices on your network, click “Start Squid”
6. Ok so step 2 is complete. You can now configure your PS3 to connect to the internet via your PC/Mac

4.  Configuring the PS3

The PS3 now needs to be told to connect to the internet via the PC/Mac with the VPN connection and proxy software. This will trick the Uk TV sites into thinking the PS3 is connecting from the UK.

Implementation

If you are not familiar with the PS3 configuration, check out the manual first here: http://manuals.playstation.net/document/en/ps3/current/settings/connectadvance.html

1. Open Settings->Network Settings ->Internet Connection Settings
2. Click Yes when promoted to disconnect from the internet temporarily, then simply browse to the Proxy Server screen (Shown Below), click “Use” then enter the IP Address and port of your PC/Mac E.G:
   • Proxy Server: 192.168.1.2
   • Port 3128
3. Save all configuration and exit the Settings menu system
4. So now the PS3 should be able to stream from the UK TV sites. To test simply go to the iPlayer icon at the home screen and try stream your favourite TV show!

Important Notes

• If the VPN is disconnected for whatever reason the proxy must be stopped, then restarted after the VPN connection is re-established.
• You are required to purchase a UK TV license if you watch UK BBC channels

Revamp your guitar electronics!

Ever wanted to upgrade your guitar electronics?

This guide shows how to install a pre-wired assembly from Rothstein guitars into a Fender Jazzmaster guitar.

There are also a few hints and tips to make this daunting task a bit easier.

Click here to download:

Fender Jazzmaster Electronics Replacement (lowres).pdf (7455 KB)