Navigating Starlink's FCC Paper Trail | Hacker News Reader

Navigating Starlink's FCC Paper Trail

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120 pointsDanAtC41 comments

> One wonders whether SpaceX’s recent ITU application through Tonga’s authorities for a constellation with nearly 30,000 satellites represents an attempt to circumvent FCC scrutiny by launching under a flag of convenience.

That Tongan Space Program - they've claimed a lot of spot reservations but haven't launched many satellites. Their budget is miniscule, less than $10m as of the early 2000s. If I'm reading correctly, they only have a single satellite.

https://en.wikipedia.org/wiki/Tongasat

Yes, that was an interesting coda to the story, closing with an example of the opening:

The rules of the game aren’t published anywhere, but the aims seem to be quite clear — as an established geostationary satellite provider fearing that SpaceX may be eating your lunch, your goal is to throw as many spanners into the works as you can, usually cleverly disguised as technical objections, to delay and suppress.

SpaceX’s goal, on the other hand, seems to be to make you spend as much money on lawyers and other experts as they can, by getting you to comment on system alternatives and options they subsequently abandon.

> they’re clearly not the kind of company that takes people on factory tours to proudly show off how they make and run things

??? SpaceX is certainly the most open space corp out there, by a mile. I mean they're still a private for profit company that has to follow ITAR rules, but compared to their competition, they're extremely open. Anyone following Starship development can see that. Just the fact that they even gave a tour (twice!) to the Everyday Astronaut, with Raptor closeups and everything... Imagine Blue Origin or Boeing doing something like that. Yea, right.

He is speaking about Starlink, not SpaceX. The whole sentence wasn't phrased correctly but that's what he meant.

Starlink gives factory tours as part of the interview process. A guy I know who didn’t even get hired saw the sat assembly line in the Seattle area.

How bad was the interview process up until then? If it's not too bad, it might be worth interviewing to get the tour...

I think he said it was pretty similar to a tech company test (4-5 on-site interviews).

Boeing gives multiple daily tours in their Everett Washington based airplane manufacturing facility. They have a public museum next to the facility which is where you buy tickets to the tour and wait for the tour shuttle. I’ve taken the tour and it’s cool!

That said I’ve not heard of any tours for their space manufacturing facility, though they might offer them.

Space manufacturing centers generally offer tours but not for the general public. It's more like a friends and family sort of deal. Even my uncle got to go inside Endeavor in the early 2000s as he was friends with a QA manager of the shuttle program.

Satellites and spaceships are classified as weapons, tours that actually showed anything to the general public without some solid verification would be a serious crime. You'd have to be a "US Person" which means generally at least green card or a citizen of a friendly country.

Like if you gave a tour to a Chinese citizen you could well be guilty of exporting protected technology.

When I was a kid my dad took me to “take your kid to work day” at Lockheed. I think they hid the secret stuff somewhere where visitors wouldn’t find them.

Mar-el-Lago?

Unlike politicians, the military + contractors take their responsibilities re. controlled information relatively seriously. The normal practice is to not have anything that is clearance-controlled sitting out anyway (it's usually stored behind extra levels of security scaled to the secrecy), and to control access to that information on a fairly granular level. Visitors to those facilities (of a variety of clearance backgrounds) are regular, so anything beyond ITAR (which you, as the child of an ITAR-accessible employee, and thus likely a US citizen/green card holder would have had access to) is going to be locked up by default.

Having grown up in North FL, I've been on a few military ships for friends and family day. This is pretty much exactly what they do. You're only allowed where they tell you to be and they have people watching to make sure you follow the rules.

If anyone gets the chance to go out on a carrier, do so. Pretty neat stuff.

I interned at a Lockheed facility (which is now a nice strip mall). The classified things are behind closed doors or in your computers. The labs where you'd work on classified equipment were behind coded doors, so they just wouldn't take anybody there. They really checked too. One time I was waiting for my friend to finish something in a non-classified lab that still had the code on the door. I was literally falling asleep for a couple of hours doing nothing so I decided not to charge those hours. A few weeks later my manager invited me into his office to reprimand me for not charging the hours because they audited the doors and knew where I was for how long. I got overtime because they tracked what was going on so well.

> You'd have to be a "US Person" which means generally at least green card or a citizen of a friendly country.

Under ITAR, “US Person” means US citizen or green card holder. (And a few other obscure categories, such as individuals granted refugee status by the US government.) Export to citizens of friendly countries (who don’t have green cards or dual US citizenship) requires an export license. I heard some talk they might exclude Australian citizens from this rule as part of AUKUS (although even there I don’t know if it would apply to space stuff, since space ain’t got nothing to do with nuclear submarines), but right now no ally is excluded.

> Like if you gave a tour to a Chinese citizen you could well be guilty of exporting protected technology.

From what I understand, theoretically speaking you are okay if they have a green card, or dual US-Chinese citizenship. How well the theory holds up in practice, I don’t know. (Technically China bans dual citizenship-however, if a Chinese citizen naturalises into the citizenship of another country, what happens if they don’t tell the PRC government they did it? And even if they do tell the PRC government, although PRC law says the government has to cancel their Chinese passport, the PRC government is free to ignore its own laws whenever it wants to.)

There are generally exceptions to US Person status for dual citizens, especially those from "Designated countries" which include China, Iran, etc currently. These exceptions apply on a per-center, per-project basis IIRC, but include blanket bans on NASA collaboration / exchange, which would include private tours of the kind being discussed.

https://www.nasa.gov/wp-content/uploads/2023/08/designated-c...

That NASA document doesn’t actually say it applies to dual citizens, it only says it applies to “Foreign Nationals”. It all depends on how one defines that term, of course, but usually in US law, a US dual citizen is not a “Foreign National”. The document never mentions the issue of dual citizenship.

Now, I’m not saying you are wrong here - maybe NASA actually does have a policy saying dual US citizens are subject to certain additional restrictions, depending on the country of dual citizenship - but the document you are citing in support of your position never actually says that.

If we are talking about security clearances, as opposed to export control, that is a completely different story. Absolutely dual citizenship can get one denied a security clearance, and dual citizenship with an unfriendly country increases those odds-but even there, there is no absolute rule about it, whether dual citizenship is disqualifying is decided on a case-by-case basis, and it depends not just on the country of dual citizenship, but also how one got the citizenship, how much one chooses to make use of its benefits (there is a big difference between getting dual citizenship at time of birth but never applying for a passport, versus naturalising as a citizen of another country as an adult and then travelling around the world with its passport), etc

>From what I understand, theoretically speaking you are okay

One does not rely on theory when you could spend a decade in prison for interpreting it wrong. For edge cases you'd better consult your compliance lawyer, your state department contact, and your god before making assumptions. Exports do happen all the time and there's a pretty open culture of declaring them. Usually it's a matter of an email getting sent to the wrong person and actually harmless which comes with an administrative bitch slap from the state department and maybe a moderate fine (like 5 digits, enough to get somebody's attention but in the way a parking ticket does). If you're brazen or particularly foolish or there's real harm though...

too bad they've been kneecapped by the business casual crowd...

>the business casual crowd...

The what now?

The Khaki Pants Mafia, The No. 2 Pencil Pushers, Auntie Plaid, you know…

I don't think fashion has much to do with it.

I have no idea to which group you're referring.

Airplane manufacture has a different export rating than spacecraft manufacture, thus (probably) the different posture re: tours. For example, at JPL (where I used to work / give tours), there's a multi-day lead time for background checks on visitors if they intend to enter any location not pre-cleared for tours. E.g., looking at equipment or actual manufacturing.

I’ve toured the SpaceX factory in Hawthorne, it was pretty cool. Was inches away from a guy cranking a wrench on a previously flown rocket engine, it was extremely cool.

...Two cool, dude, two cool.

Its actually ULA that tends to be the most transparent. It just doesn't show as much as they aren't doing nearly as much. But yes, Blue Origin is strangely secretive.

Gotta be secretive when you've got nothing to show. Keeps the illusion of progress in place.

speculation

True. But why should they be that open? I imagine SpaceX has quite a bit of intellectual property that is non trivial that they don't necessarily want to just hand over to their competition. They are doing quite a few cool things with radios in star link that I imagine are very valuable technology.

I watched the latest interviews of Everyday Astronaut over the weekend. Very nice deep dive in the current state of star ship and all the tech involved with that. But there were clearly a few details that Elon wasn't ready to discuss. Which is understandable.

As for the question at the end of the article. The FCC is a federal institution with jurisdiction in the US. SpaceX operates a global network of satellites that covers most of the planet. So, going through the ITU seems like it's not a strange move. They'll need approval from more than just the FCC to operate those 30K satellites, which presumably is what those large nice Starships that they are producing rapidly now are going to be delivering to orbit.

If my memory serves, there were at least a couple of blurred/pixellated details in that.

What I also noticed is a change in Musk from early Everyday Astronaut interviews, where rather than tackling the mention of competing technologies or methodologies witha reasoned argument as to why they weren't going that route, he'd clamp up and a few minutes later respond clearly slighted by the proposition.

Musk has always been a bit of a hard listen, but I found this last EA interview really hard to get through.

I think Musk just wanted to make the point that there are many ways to achieve rapid and reliable reusability but they have chosen this one, they are laser focused on making it work, and they know they can make it work. So other ways of doing things are actually not important to him right now.

The blurring is for ITAR compliance. It's not SpaceX policy, it's government policy.

My impression from the latest interview was that Elon has not been as directly involved in SpaceX technical decisions since buying Twitter and spending a bunch of time on that instead. So he was less able to engage on technical questions.

ULA/Tory Bruno has definitely given tours to YouTubers as well

As have Rocket Lab, Firefly, Astra (RIP probably), Stoke, Relativity, Spin Launch if that counts, and probably others.

When I worked there, you could take your family on a tour (if they were a US Citizen). There was no problem as long as people didn't touch anything on the factory floor. But things may have changed.

Spacex gave me a factory tour when I was applying so I have an anecdote in direct counter

In fairness, ULA has done that too.

https://www.youtube.com/watch?v=o0fG_lnVhHw

Also literally everything Destin/SmarterEveryDay puts online is worth watching.

One filing type they didn't mention, is SES-STA (Satellite Earth Station Special Temporal Authority) -- aka a temporary experimental license for user or gateway equipment. This is where the juice is, i.e. if they're testing out new models that haven't been announced yet, and if you're lucky includes some technical specs.

But they're hard to filter through because they file so many for uninteresting things too.

> The FCC website would be a rabbit warren even if there was no SpaceX

A relative of mine is in a dispute with another party regarding real estate.

I mention this here b/c a big part of that dispute has involved pulling data from government websites (Specifically city property records).

The below is all true:

- the amount of useful information in government websites is astounding

- the UX of these websites is awful

- given the above, if you are good at navigating these websites (or can automate the data gathering) it really can be a superpower.

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