SpaceX tells FCC that zero of Viasat's 657 proposed reference links pass the screening criteria

FCC · 25-157 · REPLY TO COMMENTS · 2026-07-14
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GSO operators "now seek to collapse that framework from within," SpaceX told the FCC in July 14 reply comments on the reference links that will implement the agency's new satellite spectrum sharing rules. The filing singles out Viasat: by SpaceX's count, every other GSO operator combined submitted 78 candidate links, while Viasat alone submitted 657, none of which satisfies the selection criteria in the Space Bureau's Public Notice. SpaceX says roughly half of Viasat's links use antennas smaller than 45 cm, including 101 links with 15 cm antennas, and calls Viasat's proposed phased array antenna pattern one it "appears to have made up out of thin air."

Applying the Public Notice criteria to everything submitted, SpaceX finds 36 valid links and asks the Bureau to adopt those and reject the rest. The docket is crowded: Orbit Sentinel counts 148 filings in 25-157 from 60 distinct parties, including 72 comments and 25 ex parte filings.

"While all other GSO operators submitted a combined 78 links, Viasat submitted a whopping 657 links—of which zero satisfy the link selection criteria specified in Appendix A of the Public Notice."

— Joseph Bissonnette, Principal, Satellite Policy, in the reply comments of Space Exploration Holdings, LLC (SpaceX), FCC docket 25-157

Sources: SpaceX Reference Link Reply Comments → · Orbit Sentinel (docket 25-157)

Filed underSpacexViasatGso Reference LinksSpectrum SharingDocket 25 157

Questions & answers

What are the GSO reference links?
Per SpaceX's filing, the FCC's Satellite Spectrum Sharing Order replaced Equivalent Power Flux Density (EPFD) limits with short-term and long-term protection criteria, and next-generation satellite systems must demonstrate compliance against a set of GSO reference links the Space Bureau maintains.
What does SpaceX want the Space Bureau to do?
Adopt the 36 submitted links that satisfy the Public Notice selection criteria as reference links and reject all links that fail to conform.
Which criteria does SpaceX say Viasat's links fail?
Per SpaceX, none of Viasat's gateway links use Adaptive Coding and Modulation, none of its links provide at least 3 dB margin on top of the margin for rain fade, roughly half use antennas smaller than 45 cm (including 101 links with 15 cm antennas), and more than half sit at elevation angles below 25 degrees.