Amazon's attempt to block proposals for the next-generation Starlink system is a "delay tactic" and a continuation of Amazon's strategy of "hinder[ing] competitors to compensate for Amazon's failure to make progress of its own," SpaceX told the Federal Communications Commission yesterday.

"Amazon's track record amply demonstrates that as it falls behind competitors, it is more than willing to use regulatory and legal processes to create obstacles designed to delay those competitors from leaving Amazon even further behind," SpaceX told the FCC in its filing. Approving Amazon's request would hurt consumers by denying them "access to faster-moving competition," SpaceX said.

Amazon last week urged the FCC to reject an update to SpaceX's Starlink plan because it "proposes two different configurations for the nearly 30,000 satellites of its Gen2 System, each of which arranges these satellites along very different orbital parameters." Amazon contends that the SpaceX request violates a rule requiring applications to be complete and have no internal inconsistencies.

Amazon's request would prevent the commission from seeking public comment on SpaceX's application, SpaceX said. "The commission should recognize this gambit for the obstructionist tactic that it is, reject Amazon's request, and quickly put the amendment out for public comment," SpaceX said. The public-comment process will allow "any issues [to] be fully vetted," SpaceX said.

Amazon’s Kuiper far behind SpaceX Starlink

Amazon's Kuiper Systems subsidiary plans to eventually launch low Earth orbit satellites to compete against SpaceX's Starlink division. But while SpaceX is providing beta service to over 100,000 customers from over 1,700 satellites, Amazon has said it won't start launching any satellites until at least 2023.

Starlink is seeking permission to launch 30,000 satellites in addition to the nearly 12,000 it already has a license for. On August 18, SpaceX proposed one configuration that "will more evenly spread capacity by latitude by targeting multiple inclinations, ensuring better, more consistent global coverage," along with a second configuration that "utilizes a smaller number of satellites per plane than Configuration 1, yet also spreads capacity more evenly by latitude for more consistent coverage across the globe." SpaceX said it prefers the first configuration in part because it "fully leverages the upgraded satellite capabilities and the availability of Starship."

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While Amazon says the proposal for two configurations breaks FCC rules, SpaceX yesterday said this argument is nonsense:

Amazon argues that the amendment should be dismissed because it provides information on SpaceX's preferred configuration as well as an alternative. Amazon alleges that SpaceX's application somehow fails the commission's requirement for "completeness," yet it does not identify any required information that SpaceX failed to provide with respect to its proposal for either of these configurations. Rather, Amazon argues that the application "leav[es] nearly every major detail unsettled"—even though all relevant parameters are meticulously set forth in the application for both configurations. Indeed, SpaceX provided technical analyses to demonstrate that neither configuration would cause unacceptable interference to other NGSO [non-geostationary satellite orbit] and or terrestrial systems operating in the band—including Amazon—and also updated the orbital debris analysis for both configurations. In effect, Amazon makes the odd argument that the application is incomplete because it provides too much information.

SpaceX criticized Amazon for apparently putting more effort into delaying Starlink plans than into updating its own:

The commission issued an order in July 2020 informing Amazon that it had not provided sufficient information about how its proposed system would protect others from interference or meet the commission's rules for orbital debris. But while Amazon has filed nothing with the commission to address these conditions on its own license for nearly 400 days, it took only 4 days to object to SpaceX's next-generation NGSO system. In fact, Amazon has not had a single meeting with the commission this year about how it intends to resolve the commission's interference or safety concerns, but it has had 15 meetings in that same span just about SpaceX. While Amazon has waited 15 months to explain how its system works, it has lodged objections to SpaceX on average about every 16 days this year.

The July 2020 order that SpaceX referred to gave Amazon approval to launch 3,236 satellites but ruled that Amazon must still demonstrate that Kuiper won't interfere with other systems, provide a complete orbital-debris mitigation plan, and meet other requirements.

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SpaceX says Amazon’s plan is the speculative one

Amazon's protest said the FCC requires applications to be complete and have no internal inconsistencies in order to avoid encouraging "speculative applications." SpaceX argued that Amazon's application is the speculative one:

Amazon cannot explain how providing information to the commission about an alternative configuration would encourage speculation. In fact, one would normally expect Amazon to welcome flexibility, given how much Amazon has struggled to address the fundamental shortcomings the commission identified in its own speculative proposal and the fact that it has not even selected launch providers for all of its satellites.

SpaceX said it provided two potential configurations for the next-generation Starlink deployment because plans could change "depending on the timing of development of the satellites and launch vehicle for which SpaceX has exercised radical transparency. The commission no doubt would have the wherewithal and sophistication to distinguish an actual system like SpaceX's from an application that is merely a pretext."

Amazon complained that SpaceX's dual-configuration proposal "doubles the technical effort" that it and other satellite operators face when "reviewing the interference and orbital debris concerns raised by SpaceX's amendment." SpaceX countered that "Amazon strains credulity by suggesting it lacks the resources to analyze SpaceX's application, especially considering Amazon routinely brings as many as six lobbyists and lawyers to its many meetings with the commission about SpaceX."

SpaceX cites Bezos “bottleneck” quote

SpaceX acknowledged that providing two possible configurations is unusual in the US but said the approach is "familiar to many satellite operators from its use by the International Telecommunication Union. While the orbital parameters differ slightly, neither configuration requires additional spectrum, neither will result in additional interference to other proposed NGSO systems, and both will comply with the commission's rules to the same extent as its current constellation."

SpaceX concluded its filing by pointing to a recent quote from Amazon founder Jeff Bezos. "As Amazon's former chief executive has said in the past, procedural maneuvers—like the ones Amazon now deploys—have 'become the bigger bottleneck than the technology,'" SpaceX told the FCC.

Amazon declined to comment on SpaceX's filing when contacted by Ars today.