This Supplemental Engineering Exhibit provides a performance-based safety case for high-power (~100 kW peak) duty-cycled orbital compute satellites of approximately one-metric-ton mass class, submitted in connection with the SpaceX Orbital Data Center System application. This exhibit is intentionally structured to assist the Commission’s performance-based licensing approach and the proposed “expedited processing / bright-line criteria” construct described in SB Docket 25-306. The analysis also maps directly to the Commission’s orbital debris mitigation requirements, including the five-year post-mission disposal (PMD) benchmark for LEO satellites. Principal conclusion: With explicit (i) structural verification targets, (ii) high-temperature power electronics selection and thermal architecture, (iii) propulsion power allocation policy, (iv) CAM power reserve policy, and (v) PMD reliability engineering, the proposed ~100 kW architecture can be implemented with safety margins equal to or better than lower-power, bulkier legacy designs - because it provides disposal and maneuver authority margin that directly reduces debris exposure time and collision risk. As FCC moves toward a performance-based licensing framework under the “Space Modernization for the 21st Century” (SB Docket No. 25-306), the public record requires robust, quantitative substantiation of novel spacecraft architectures. Our independent first-principles assessment provides the "substantial evidence" necessary to establish the technical plausibility and safety of high-power (~100 kW) duty-cycled orbital compute nodes.Specifically, this submission fills the evidentiary record in four critical areas: Administrative Procedure Act (APA) Compliance: We provide the quantitative "how" that supports the Commission’s "substantial record" requirements, insulating a future grant from "arbitrary and capricious" challenges. Orbital Debris Mitigation: Our analysis demonstrates that the 100 kW architecture enables days-scale to sub-week post-mission disposal (PMD), vastly exceeding the Commission’s five-year benchmark. Safety Envelope Certification: We establish "Bright-Line" structural and thermal verification targets that allow the Space Bureau to classify this modular architecture as a "Safe Harbor" design for expedited processing. Public Interest Justification: We provide data-driven evidence of the terrestrial power and water savings afforded by orbital compute, satisfying the high legal threshold for the requested regulatory waivers. By incorporating this independent third-party validation into the record, the Commission can ensure that its final Order is technically sound, legally defensible, and aligned with the "Licensing Assembly Line" goals of the Space Bureau.
Sanjay Kumar (Tue,) studied this question.