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Multiple mega-constellations of satellites could take root in low Earth orbit over the next few years. (European Space Agency Illustration)

Amazon fired its latest volley today in a back-and-forth debate over whether the company can proceed in an expedited fashion with its 3,236-satellite Project Kuiper mega-constellation for broadband internet access.

Today’s 24-page letter to the Federal Communications Commission addresses objections raised by SpaceX, OneWeb and other mega-constellation ventures to Amazon’s request for an “expeditious grant” of its application to launch and operate the Kuiper satellites.

“Affording equitable access to spectrum and orbital resources will increase investment, innovation, and consumer choice.” Mariah Dodson Shuman, corporate counsel for Kuiper Systems, Amazon’s satellite subsidiary, wrote in the letter.

Read the letter: Amazon argues the case for Project Kuiper in FCC filing

Like SpaceX and OneWeb, Amazon says it aims to provide broadband service from low Earth orbit, or LEO, for billions of people around the world who are currently underserved. Amazon executives also say Kuiper could boost the company’s other lines of business, ranging from online retailing to cloud computing.

Project Kuiper, however, is a relative latecomer to the mega-constellation game: SpaceX and OneWeb made their first filings with the FCC years ago, received the FCC’s OK to start creating their constellations in 2018 and have already put satellites in low Earth orbit. In contrast, Project Kuiper came out into the open only last April. Amazon hasn’t yet announced a timetable for launch or operation, and today’s letter suggests the Kuiper satellite design is still in the works.

In a series of arguments filed over the past few months, Amazon’s rivals say Project Kuiper should wait for a future frequency licensing round rather than getting a waiver from the FCC to enter the current round. SpaceX asserted that having to share Ka-band spectrum with Amazon would unfairly degrade its own Starlink service, which could go into limited operation as early as this year. (Sixty more Starlink satellites are due for launch no earlier than Wednesday.)

In today’s response, Amazon said its own “conservative simulations” showed that Project Kuiper “neither materially impacts the interference environment for existing licensees, nor precludes future entry.” The letter raised several technical points questioning SpaceX’s claims about potential interference.

In making its assessment, Amazon took a couple of factors into account. One factor is the assumption that SpaceX and other players would engage in “good-faith coordination” to minimize the potential for satellite interference, in accordance with FCC rules. Experts have said that as the number of satellites in low Earth orbit rises, the need for a unified satellite tracking and avoidance system will become increasingly critical.

The other factor has to do with the exit of Boeing and LeoSat from the competition for spectrum. Boeing withdrew its application for a Ka-band frequency constellation in mid-2018, while LeoSat’s grant of market access was revoked last year. Amazon argues that those exits made more than enough room for Project Kuiper.

The letter says Kuiper will take advantage of technical twists that Boeing’s system would have lacked, including small spot beams, satellite diversity, low orbital altitude and frequency agility. “The Kuiper System not only has a far lower potential for interference, but also is far less susceptible to interference and far more flexible than the abandoned Boeing and LeoSat systems would have been,” Amazon said.

Today’s letter touches on the issue of orbital debris only in general terms, saying that Amazon “will satisfy international and national space safety standards to limit orbital debris.”

Amazon said it would submit a detailed orbital debris analysis “when it has finalized the Kuiper System’s satellite materials and components.” In the meantime, Amazon suggests that the FCC could say its go-ahead is conditioned on the submission and approval of that analysis.

The letter doesn’t touch upon an issue that rose to the fore once SpaceX started deploying its Starlink satellites: the potential for satellites to reflect the sun’s glare, spoiling astronomical observations in the process.

SpaceX says it’s testing a manufacturing method that should reduce the glare, but it’s too early to determine whether that method is workable — and it’s not at all clear whether Amazon or OneWeb are working on methods for reflection reduction.

It is clear, however, that Amazon is continuing to expand its Project Kuiper team. The company’s career website lists 175 open positions for the project, including jobs that are related to the development of laser-based satellite communications.

All this doesn’t come cheap, and Amazon clearly doesn’t want to be shut out of the market. In today’s letter, the company says winning the FCC’s go-ahead on an expedited basis will give it “regulatory certainty that facilitates its investment of billions of dollars in its next-generation constellation, associated ground infrastructure, and other capabilities necessary to support a global broadband satellite system.”

Hat tip to the Megaconstellations Twitter account.

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