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	<title>TMF Associates blog &#187; Regulatory</title>
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	<link>https://tmfassociates.com/blog</link>
	<description>Satellites, spectrum and other stuff</description>
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		<title>Starlink&#8217;s German alignment</title>
		<link>https://tmfassociates.com/blog/2026/03/02/starlinks-german-alignment/</link>
		<comments>https://tmfassociates.com/blog/2026/03/02/starlinks-german-alignment/#comments</comments>
		<pubDate>Mon, 02 Mar 2026 15:36:06 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[Aeronautical]]></category>
		<category><![CDATA[D2D]]></category>
		<category><![CDATA[Globalstar]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[Services]]></category>
		<category><![CDATA[SpaceX]]></category>
		<category><![CDATA[Spectrum]]></category>
		<category><![CDATA[T-Mobile]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6910</guid>
		<description><![CDATA[It was fascinating to see today&#8217;s announcement at MWC, that Starlink is partnering with Deutsche Telekom to &#8220;support over 140M subscribers across 10 European countries&#8220;. Most remarkable is that DT is explicitly confirming that &#8220;the service will operate only in Starlink’s MSS (Mobile Satellite Service) spectrum&#8221;, effectively treating renewal of EchoStar&#8217;s existing 2GHz MSS license [...]]]></description>
			<content:encoded><![CDATA[<p>It was fascinating to see today&#8217;s announcement at MWC, that <a href="https://www.telekom.com/en/media/media-information/archive/telekom-and-starlink-satellite-to-mobile-for-europe-1103000">Starlink is partnering with Deutsche Telekom</a> to &#8220;<a href="https://x.com/Starlink/status/2028459012363309232">support over 140M subscribers across 10 European countries</a>&#8220;. Most remarkable is that DT is explicitly confirming that &#8220;the service will operate only in Starlink’s MSS (Mobile Satellite Service) spectrum&#8221;, effectively treating renewal of EchoStar&#8217;s existing 2GHz MSS license in Europe as a <em>fait accompli</em>.</p>
<p>That&#8217;s perhaps not surprising, because I&#8217;m told that an announcement from the EU on the process for reallocating the 2GHz licenses after they expire in spring 2027 remains stalled, and may take several more months to emerge. As a result, the expectation is that the current licenses (held by Viasat and EchoStar) will be extended, probably by two years, to allow time for that process (with appeals and a need for subsequent actions by national regulators) to conclude.</p>
<p>But there is a wider context here to the alignment between Starlink and Deutsche Telekom here, which is seemingly happening with the implicit backing of the German government (and makes me wonder <a href="https://www.nbcrightnow.com/national/showdown-looms-between-tesla-and-german-union/article_4076902c-eb51-5242-be4a-848ae5372f90.html">what will happen to Tesla&#8217;s factory in Germany this week</a>).</p>
<p>Back in January, news broke that Starlink had struck a fleetwide deal to <a href="https://newsroom.lufthansagroup.com/en/new-lufthansa-group-collaboration-with-starlink-high-speed-internet-on-all-fleets-across-all-airlines/">equip Lufthansa&#8217;s aircraft</a> with connectivity. After the prior <a href="https://www.satellitetoday.com/mobility/2025/11/06/international-airlines-group-to-implement-starlink-across-5-airlines/">loss of IAG to Starlink</a> in November 2025, Lufthansa was the last remaining anchor customer for Viasat&#8217;s European Aviation Network (EAN).</p>
<p>Lufthansa&#8217;s defection fatally undermined the case to retain EAN in its current form and therefore has called into question the need for Viasat to retain 2x15MHz for its 2GHz MSS license. In supporting Viasat&#8217;s application for renewal, Lufthansa had even gone as far as to claim that <a href="https://tmfassociates.com/blog/wp-content/uploads/2026/03/03_Lufthansa-Group.pdf">&#8220;The EAN is a critical building block in continuing our journey to offer an industry-leading connectivity solution to our passengers.&#8221;</a> Of course, it will take some time to replace the EAN terminals on both Lufthansa and IAG, but that just reinforces the rationale for a two-year extension to the current European 2GHz licenses, before any changes take place.</p>
<p>Those changes could potentially reduce both Viasat and EchoStar to paired 10MHz blocks and free up a third license for a European provider (prompting a fight between the AST/Vodafone partnership and the SES/Lynk/Omnispace grouping). But now I wonder if DT might switch its position and suggest cutting Viasat to 2x10MHz, in order to free up 2x5MHz for IoT, while leaving EchoStar/Starlink with the full 2x15MHz. Though whether that would fly with EU regulators is far from clear.</p>
<p>What is interesting is that Lufthansa&#8217;s decision to defect to Starlink was apparently very sudden, in fact I&#8217;m told that Lufthansa had been negotiating a major deal with another IFC provider for the last couple of years, which was close to being confirmed publicly, and rumors suggest that the German government had a hand in the switch.</p>
<p>Now we have a similar major deal between Deutsche Telekom and Starlink that comes after <a href="https://www.semafor.com/article/08/28/2025/att-won-the-first-battle-for-spectrum-elon-musk-and-amazon-could-be-next">DT reportedly vetoed T-Mobile US&#8217;s plan to buy EchoStar&#8217;s spectrum last summer</a> to enhance the partnership between TMUS and Starlink. And last June, DT had been just as unenthusiastic about any changes to the 2GHz band, <a href="https://tmfassociates.com/blog/wp-content/uploads/2026/03/14_Deutsche-Telecom.pdf">stating that</a> &#8220;Deutsche Telekom AG plans to continue operating the European Aviation Network (EAN) using the MSS 2GHz spectrum beyond 2027&#8230;preserving the current spectrum allocation is crucial for the continued operation and economic viability of the EAN.&#8221;</p>
<p>So the natural question is &#8220;what changed&#8221;? I&#8217;m told that even after vetoing the TMUS-EchoStar spectrum deal (and then replacing the TMUS CEO while privately characterizing TMUS as &#8220;going rogue&#8221;), DT continued investigating D2D options and was one of three companies that looked at Globalstar when that asset was <a href="https://www.fierce-network.com/wireless/globalstar-stays-mum-possible-sale-company">put up for sale last fall</a> (the other two being SpaceX and Apple).</p>
<p>But nothing happened there, and now DT has decided instead to strike a major partnership with Starlink, preferring to rely on the 2GHz MSS band over Globalstar&#8217;s Big LEO spectrum. And there&#8217;s even a DT panelist (Jaroslav Holis) <a href="https://www.mwcbarcelona.com/agenda/speakers/18099-jaroslav-holis">scheduled to speak</a> at the Equatys event on Wednesday which raises the question of what DT might have been exploring there. So I&#8217;m left wondering whether there are wider German political factors behind the decisions of both Lufthansa <em>and</em> Deutsche Telekom to reverse themselves in short order.</p>
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		<title>The problem with Starship</title>
		<link>https://tmfassociates.com/blog/2026/02/08/the-problem-with-starship/</link>
		<comments>https://tmfassociates.com/blog/2026/02/08/the-problem-with-starship/#comments</comments>
		<pubDate>Sun, 08 Feb 2026 22:29:55 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[Broadband]]></category>
		<category><![CDATA[Financials]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[SpaceX]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6898</guid>
		<description><![CDATA[On Friday, redacted versions of two SpaceX financial forecasts, one from 2021 and the other from 2023, were disclosed in the Delaware litigation between SpaceX shareholders. While only very limited numbers in the financial projections remain unredacted (beyond the expectation in the 2021 forecast that &#8220;government&#8221; revenue for Starlink would grow to $5B by 2027), [...]]]></description>
			<content:encoded><![CDATA[<p>On Friday, redacted versions of two SpaceX financial forecasts, <a href="https://tmfassociates.com/blog/wp-content/uploads/2026/02/2026.02.06-JX_054-REDACTED-PUBLIC-VERSION.pdf">one from 2021</a> and the <a href="https://tmfassociates.com/blog/wp-content/uploads/2026/02/2026.02.06-JX_540-REDACTED-PUBLIC-VERSION.pdf">other from 2023</a>, were disclosed in the <a href="https://courts.delaware.gov/Opinions/Download.aspx?id=384850">Delaware litigation between SpaceX shareholders.</a></p>
<p>While only very limited numbers in the financial projections remain unredacted (beyond the expectation in the 2021 forecast that &#8220;government&#8221; revenue for Starlink would grow to $5B by 2027), there is enough that can be extracted to determine that Starlink has exceeded the 2021 revenue forecast, but Starship has fallen dramatically behind expectations even in 2023. The 2021 forecast helpfully used redactions matched to the number of characters, showing that Starlink was first expected to exceed $10B in revenues in 2026, while in actual fact Starlink passed $10B in 2025.</p>
<p>The projected valuations on the last page of this document also make it possible to back into the total company revenues forecast in 2021 and 2027: the $102.8B valuation was 25x revenues, implying a revenue forecast of $4113M for 2021. By 2027 this valuation was expected to have increased 4.9x, to around $500B, which was said to be 20x revenues, implying a revenue forecast of ~$25B for 2027. That again is slightly less than SpaceX&#8217;s likely total revenues in 2027, even if you remain skeptical about SpaceX&#8217;s ability to meet the <a href="https://www.bloomberg.com/news/articles/2025-12-09/spacex-said-to-pursue-2026-ipo-raising-far-above-30-billion">current published 2026 forecast of $22B-$24B</a>.</p>
<p>However, the 2023 forecast shows how SpaceX was expecting Starship to start launching Starlink satellites to orbit in 2024, with Falcon 9 phased out for Starlink launches in 2026. Now even on Musk&#8217;s optimistic timeline from December 2025, Starlink V3 launches on Starship aren&#8217;t <a href="https://www.pcmag.com/news/elon-musk-eyes-mass-deployment-of-v3-starlink-satellites-in-q4-2026?test_uuid=04IpBmWGZleS0I0J3epvMrC&#038;test_variant=A">expected &#8220;at scale&#8221; until &#8220;around Q4&#8243; of this year</a>. So Starship launches of usable payloads have now consistently remained 12 months out for nearly three years.</p>
<p>It&#8217;s also fascinating to me how the ongoing debate about orbital data centers tends to ignore launch constraints. SpaceX is <a href="https://x.com/michaelnicollsx/status/2019798204162646199">just beginning to scale up</a> to develop these &#8220;AI satellites&#8221;, but until now the emphasis for Starship has been on getting it ready to launch Starlink V3 in volume. That&#8217;s meant <a href="https://www.nasaspaceflight.com/2026/01/florida-starship-progress-ksc-cape/">building extensive launch pad infrastructure in Florida</a> and <a href="https://www.nasaspaceflight.com/2026/01/faa-advances-approval-44-starship-launches-39a/">seeking permission for a high launch tempo</a> there.</p>
<p>Florida is ideal for Starlink launches to 40 and 50 degree inclinations, which will be much more difficult in Boca Chica. However, Florida is a terrible location for sun synchronous launches, which is where these <a href="https://research.google/blog/exploring-a-space-based-scalable-ai-infrastructure-system-design/">orbital data centers are supposed to go</a>, to utilize maximum sunlight. Back in 2020, SpaceX conducted the <a href="https://www.spaceflorida.gov/news/cape-canaveral-spaceport-supports-polar-launch-capabilities">first sun synchronous launch from Florida in more than 50 years</a>, and has continued to launch some Transporter rideshare missions to sun synchronous orbits since then, but this requires a very fuel inefficient &#8220;dog leg&#8221; maneuver and so is only suitable for light payloads, not bulk launches of AI satellites.</p>
<p>Similarly, undertaking sun synchronous launches from Boca Chica would be extremely challenging (and potentially cause an international dispute), as these rockets would need to fly completely across Mexico, not over the open ocean. That&#8217;s why Vandenberg is typically used for sun synchronous missions, but SpaceX hasn&#8217;t even begun building a Starship pad there, and a high launch tempo is likely to be very politically controversial in California. So how exactly does SpaceX intend to get these AI satellites to the desired orbit?</p>
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		<title>SpaceX disrupts everyone&#8217;s plans again&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/09/08/spacex-disrupts-everyones-plans-again/</link>
		<comments>https://tmfassociates.com/blog/2025/09/08/spacex-disrupts-everyones-plans-again/#comments</comments>
		<pubDate>Mon, 08 Sep 2025 13:47:55 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AST SpaceMobile]]></category>
		<category><![CDATA[Echostar]]></category>
		<category><![CDATA[Globalstar]]></category>
		<category><![CDATA[LightSquared]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[SpaceX]]></category>
		<category><![CDATA[Spectrum]]></category>
		<category><![CDATA[T-Mobile]]></category>
		<category><![CDATA[Thuraya]]></category>
		<category><![CDATA[Verizon]]></category>
		<category><![CDATA[ViaSat]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6840</guid>
		<description><![CDATA[My post last week on the potential scenarios for EchoStar assumed that the buyer of EchoStar&#8217;s spectrum would be a terrestrial player, because only using the spectrum terrestrially could produce a return that justified paying Charlie Ergen&#8217;s asking price. 12 months ago that was true when the rumors were that SpaceX was only willing to [...]]]></description>
			<content:encoded><![CDATA[<p>My <a href="https://tmfassociates.com/blog/2025/08/31/whats-next-for-echostar/">post last week</a> on the potential scenarios for EchoStar assumed that the buyer of EchoStar&#8217;s spectrum would be a terrestrial player, because only using the spectrum terrestrially could produce a return that justified paying Charlie Ergen&#8217;s asking price. 12 months ago that was true when <a href="https://x.com/TMFAssociates/status/1835770743746941002">the rumors were</a> that SpaceX was only willing to pay a few billion dollars for access to EchoStar&#8217;s AWS-4 spectrum.</p>
<p>With Deutsche Telekom apparently getting cold feet about buying spectrum for D2D, and Verizon not yet at the table, that meant the most likely scenario was for EchoStar to continue moving forward with its own constellation, in order to keep control of the whole AWS-4 block and significantly constrain Starlink&#8217;s D2D capacity in the US (while having the opportunity to monetize the spectrum in urban areas through leases to a wireless operator like Verizon).</p>
<p>But ROI has never been the primary determinant of SpaceX&#8217;s decisions, when the opportunity presents itself to dominate an industry and force competitors out. That&#8217;s why we are seeing aggressive actions from Starlink in the satellite broadband market, lowering prices for hardware and service in both the consumer and professional markets to make Amazon Kuiper&#8217;s entry harder (including a <a href="https://elcome.com/starlink-global-priority-unlimited-plan-for-imo-registered-merchant-vessels/">new unlimited maritime plan for merchant vessels at only $2500 per month</a>, which will also undermine Viasat&#8217;s NexusWave).</p>
<p>And in this case, by <a href="https://ir.echostar.com/news-releases/news-release-details/echostar-announces-spectrum-sale-and-commercial-agreement-spacex">spending $17B</a>, SpaceX has not only persuaded EchoStar to give up its D2D plans but has now made it much harder for any competitor to move forward when they can&#8217;t possibly compete with SpaceX&#8217;s speed in bringing new satellites to market. That was evident in the <a href="https://www.theinformation.com/articles/apples-satellite-ambitions-threatened-elon-musk-internal-resistance">article published by The Information</a> in May, where Apple staff working on the D2D project with Globalstar expressed concerns that their bosses would cancel the effort and decide to partner with SpaceX instead. And we&#8217;ve seen <a href="https://tmfassociates.com/blog/2025/08/08/choose-carefully-charlie/">more on that front in recent months</a>, as Globalstar&#8217;s new satellites have been delayed, and Apple was apparently forced to support Starlink on the iPhone 13 in order to secure a new launch slot.</p>
<p>It shouldn&#8217;t be ignored that <a href="https://the-mobile-network.com/2022/09/apple-iphone-14-direct-to-satellite-and-the-others/">just like in fall 2022</a>, the SpaceX announcement comes right before <a href="https://www.macrumors.com/guide/september-2025-apple-event-what-to-expect/">Apple&#8217;s own event tomorrow</a> to announce its new iPhone. So while this might not be on the agenda tomorrow, decisions about the future of the Apple-Globalstar partnership and the new C-3 constellation will be on everyone&#8217;s minds. The <a href="https://mda-en.investorroom.com/2025-09-08-MDA-SPACE-PROVIDES-UPDATE-ON-ECHOSTAR-CONTRACT">cancellation of the EchoStar D2D constellation</a> was already a major blow for MDA, but any decision by Apple to pull back from the C-3 constellation would be even more devastating.</p>
<p>SpaceX especially wants Apple to cooperate instead of pursuing the C-3 constellation because the H-block and AWS-4 spectrum, that SpaceX is now acquiring from EchoStar, is not supported by any current phones (EchoStar&#8217;s Band 66 and Band 70 used different frequency pairings). Thus support from device manufacturers will be needed to get the new capabilities enabled by this spectrum into consumers&#8217; hands in the near term. Of course if Apple doesn&#8217;t come around, then there&#8217;s always the possibility that SpaceX will announce a &#8220;Starlink phone&#8221; as Apple executives worried about in the May article.</p>
<blockquote><p>In recent years, Musk has also plotted the ultimate challenge to Apple, said a person with direct knowledge of his thinking: building his own phone to get around Apple’s gatekeeper position in the market. Musk has discussed Tesla building the phone and providing satellite connectivity through Starlink, the person said.</p>
<p>Musk hasn’t kept his openness to making a smartphone secret. He has publicly toyed with the idea on social media at times, but he has also made it clear he doesn’t want to deal with the headaches of such a monumental effort.</p>
<p>“The idea of making a phone makes me want to die,” Musk <a href="https://x.com/ElonClipsX/status/1847490242183352484">said at a Trump rally in Philadelphia last October</a>. “If we have to make a phone, we will. But we will aspire not to make a phone.”</p></blockquote>
<p>And as far as other competitors go, AST is already struggling with enormous delays, which are now even worse than <a href="https://tmfassociates.com/blog/2025/08/12/delays-delays/">the company indicated in mid August</a>, after the FM1 satellite <a href="https://x.com/TMFAssociates/status/1963945082983239751">wasn&#8217;t ready to ship</a> at the end of August as promised during AST&#8217;s Q2 results. And AST needs to raise over $400M in the next few weeks to make the <a href="https://investors.viasat.com/news-releases/news-release-details/viasat-announces-comprehensive-agreement-ligado-networks">$420M payment due to Viasat at the end of October</a>. The one good piece of news for AST from this deal is that it very likely means EchoStar won&#8217;t retain its EU 2GHz license (though there will undoubtedly be litigation if it is cancelled), leaving AST/Vodafone in competition with SES/Lynk for what will presumably by a paired 10MHz license (assuming Viasat retains its own paired 15MHz license).</p>
<p>It&#8217;s also unclear what Viasat will do next, as the company hoped to secure financial backing from UAE-based Space42 to build its own LEO L-band network. While I don&#8217;t think a formal deal was likely to be announced next week in Paris, this announcement probably gives Space42 further pause about whether it makes sense to challenge Starlink in the D2D market, especially as the expectation was for Space42 and the UAE government to put up most of the funding.</p>
<p>Finally, I think we can now look to EchoStar to gradually wind down the rest of its operations and sell off its remaining spectrum. The remaining major block is AWS-3, which Verizon might pick up in the next few months, potentially at a discount to the $10B EchoStar paid, especially if Verizon takes on the AWS-3 reauction obligations. And then it would be reasonable to assume that DISH DBS would merge with DirecTV and Hughes could eventually be sold (perhaps to a private equity buyer?).</p>
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		<title>What&#8217;s next for EchoStar?</title>
		<link>https://tmfassociates.com/blog/2025/08/31/whats-next-for-echostar/</link>
		<comments>https://tmfassociates.com/blog/2025/08/31/whats-next-for-echostar/#comments</comments>
		<pubDate>Sun, 31 Aug 2025 17:15:54 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AT&T]]></category>
		<category><![CDATA[Echostar]]></category>
		<category><![CDATA[Financials]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[SpaceX]]></category>
		<category><![CDATA[Spectrum]]></category>
		<category><![CDATA[T-Mobile]]></category>
		<category><![CDATA[Verizon]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6824</guid>
		<description><![CDATA[Last week, EchoStar and AT&#038;T announced a landmark spectrum deal, under which EchoStar will sell all of its 3.45GHz and 600MHz spectrum holdings to AT&#038;T for $22.65B. But many analysts think &#8220;this is just the first step and the process is not yet complete&#8220;, not least because EchoStar CEO Akhavan commented that &#8220;We continue to [...]]]></description>
			<content:encoded><![CDATA[<p>Last week, <a href="https://ir.echostar.com/static-files/9b081f3a-6d9f-48a6-b350-735a9052ffc3">EchoStar</a> and <a href="https://about.att.com/story/2025/echostar.html">AT&#038;T</a> announced a landmark spectrum deal, under which EchoStar will sell all of its 3.45GHz and 600MHz spectrum holdings to AT&#038;T for $22.65B. But many analysts think &#8220;<a href="https://lightshedtmt.com/2025/08/27/carr-reset-the-wireless-industry-and-musk-may-rewrite-the-game/">this is just the first step and the process is not yet complete</a>&#8220;, not least because EchoStar CEO Akhavan commented that &#8220;We continue to evaluate strategic opportunities for our remaining spectrum portfolio in partnership with the U.S. government and wireless industry participants&#8221;.</p>
<p>The big prize now is EchoStar&#8217;s collection of midband assets in the AWS-3, H-block and AWS-4 bands, which could collectively be valued at as much as $30B. <a href="https://www.semafor.com/article/08/26/2025/echostar-musk-starlink-tmobile-spectrum">Semafor suggested</a> that a three-way deal between AT&#038;T, T-Mobile and EchoStar had been discussed under which AT&#038;T and T-Mobile &#8220;would have swapped some of their own spectrum holdings&#8221;, but <a href="https://www.semafor.com/article/08/28/2025/att-won-the-first-battle-for-spectrum-elon-musk-and-amazon-could-be-next">later indicated that</a> &#8220;T-Mobile&#8217;s ultimate owners, Deutsche Telekom, tapped the brakes&#8221;.</p>
<p>This has caused speculation to focus on Starlink and even Kuiper as potential buyers of these assets, but what many articles are getting wrong is the suggestion that this is because (as Semafor put it) Starlink &#8220;wants its own network to provide cell coverage, something that would disrupt the stranglehold that AT&#038;T, Verizon, and T-Mobile have on the US market&#8221;.</p>
<p>That&#8217;s a complete misunderstanding of the Direct-to-Device (D2D) business, which (despite the nonsense promulgated by some AST SpaceMobile investors) is limited to much slower speeds and far less capacity than terrestrial networks. It&#8217;s a <a href="https://wia.org/satellite-d2d-and-terrestrial/">simple matter of physics</a> that communicating from your smartphone to a satellite hundreds of miles up in space will be less efficient than communicating with a cell tower a mile or two away and that means D2D is <strong>not</strong> a true substitute for terrestrial cellular service.</p>
<p>The consequence of this lower throughput and capacity is that D2D can&#8217;t generate the same revenue from each MHz of spectrum in space as a terrestrial operator on the ground, and so D2D operators can&#8217;t afford to pay as much to acquire spectrum. That&#8217;s why we&#8217;ve seen <a href="https://summitridgegroup.com/spectrum-for-direct-to-device-operators/">increased interest in cheaper MSS spectrum</a>, both from Apple investing in Globalstar and more recently AST SpaceMobile bidding for Ligado&#8217;s spectrum.</p>
<p>But EchoStar&#8217;s mooted $30B price tag is only achievable by buying this spectrum for use in a terrestrial network, which is why Starlink has been trying to persuade the FCC to award it some of EchoStar&#8217;s spectrum for free. If that doesn&#8217;t work out then Starlink needs T-Mobile to pay the vast majority (if not all) of the $30B that EchoStar is demanding. So if T-Mobile steps back and we see FCC Chairman Carr accepting EchoStar&#8217;s offer to sell spectrum (and canceling the idea of a 2GHz MSS NPRM that might open up the band for sharing with Starlink), there&#8217;s no realistic prospect of Starlink and EchoStar agreeing on price.</p>
<p>We&#8217;d guess that Deutsche Telekom might want to wait for more evidence of the success or otherwise of T-Mobile&#8217;s D2D collaboration with Starlink before paying tens of billions for spectrum that they don&#8217;t really need, mainly so Starlink can improve the capacity of its D2D network. But if T-Mobile did in the end decide to bid, then either Starlink could buy the H-block (which cost EchoStar only $1.5B) and extend its existing G-block SCS network from 5x5MHz to 10x10MHz, or T-Mobile could offer Starlink access to some of the AWS-4 spectrum in rural areas for D2D.</p>
<p>However, there&#8217;s also an alternative path for T-Mobile and AT&#038;T to just swap the 600MHz holdings that AT&#038;T has now agreed to buy from EchoStar, for T-Mobile&#8217;s C-band spectrum assets, and not do any further deal with EchoStar.</p>
<p>If T-Mobile did buy all of EchoStar&#8217;s midband spectrum, then of course EchoStar&#8217;s planned D2D constellation would be abandoned. But there&#8217;s no reason to treat that as the default outcome. If instead Verizon puts in a bid for EchoStar&#8217;s midband holdings, then it isn&#8217;t allied with Starlink and wouldn&#8217;t want to risk the possibility that the FCC grants Starlink access to the 2GHz MSS band for D2D and impairs Verizon&#8217;s terrestrial usage plans.</p>
<p>So the best way forward would be for EchoStar to go ahead with its own proposed D2D constellation in order to keep exclusive access to the 2GHz MSS band in the US. Then Verizon could buy EchoStar&#8217;s AWS-3 and H-block holdings and lease AWS-4 from EchoStar in urban areas, while EchoStar coordinates D2D usage in rural and remote areas outside the reach of Verizon&#8217;s towers.</p>
<p>And finally if neither T-Mobile nor Verizon show up with an acceptable bid, then EchoStar will still want to preserve its MSS spectrum rights (and the associated terrestrial spectrum value in the US) by going ahead with the planned D2D constellation. Thus there are four possible scenarios and only in the first of them would EchoStar&#8217;s D2D constellation be abandoned:</p>
<p>1) T-Mobile buys all of EchoStar&#8217;s midband spectrum (and shares some with Starlink)<br />
2) T-Mobile just does a swap with AT&#038;T (600MHz for C-band)<br />
3) Verizon buys EchoStar&#8217;s AWS-3 spectrum and leases AWS-4 in urban areas<br />
4) No one shows up with $30B to meet EchoStar&#8217;s asking price.</p>
<p>On balance, assuming FCC Chairman Carr accepts the current EchoStar-AT&#038;T deal, it therefore seems more likely than not that at least the first stage of EchoStar&#8217;s constellation will be built. And analysts who assume it won&#8217;t be and that Charlie Ergen is simply planning to sell up and retire might instead find themselves watching this show for many more years to come.</p>
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		<title>Those who cannot remember the past are condemned to repeat it&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/08/14/those-who-cannot-remember-the-past-are-condemned-to-repeat-it/</link>
		<comments>https://tmfassociates.com/blog/2025/08/14/those-who-cannot-remember-the-past-are-condemned-to-repeat-it/#comments</comments>
		<pubDate>Fri, 15 Aug 2025 05:02:31 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AST SpaceMobile]]></category>
		<category><![CDATA[Financials]]></category>
		<category><![CDATA[Inmarsat]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[Spectrum]]></category>
		<category><![CDATA[ViaSat]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6804</guid>
		<description><![CDATA[The famous saying from George Santayana is one that often comes to mind in the MSS industry, where companies repeatedly make the same mistakes as their predecessors a decade or two ago. And this blog has plenty of posts from 2009-14 about the mistakes made by MSV/LightSquared and Phil Falcone (who incidentally was so irritated [...]]]></description>
			<content:encoded><![CDATA[<p>The famous saying from George Santayana is one that often comes to mind in the MSS industry, where companies repeatedly make the same mistakes as their predecessors a decade or two ago. And this blog has plenty of posts from 2009-14 about the mistakes made by MSV/LightSquared and Phil Falcone (who incidentally was so irritated by my posts that he was moved to <a href="https://tmfassociates.com/blog/2011/08/22/place-your-bets/">comment on one of them from his Harbinger Capital computer</a> &#8211; which is why my <a href="https://x.com/TMFAssociates">X/Twitter bio</a> says that &#8220;I enjoy annoying billionaires&#8221;).</p>
<p>So it&#8217;s now particularly ironic to see that ancient history once again take center stage in the industry as the dispute between Viasat and Ligado/AST heats up. While Phil Falcone has <a href="https://www.artnews.com/art-news/news/philip-falcone-blce-art-loans-picasso-hirst-ruling-1234748812/">other things on his mind</a> nowadays, some of us remember those days only too well, including Jennifer Manner, who <a href="https://www.linkedin.com/in/jennifer-manner-6517752/">worked at MSV/SkyTerra from 2005-2009</a>. Back then, Inmarsat and MSV signed a 100 year long Cooperation Agreement which was hugely advantageous to Inmarsat and has been a millstone around Ligado&#8217;s neck ever since. It has also been the source of endless disputes over the years as Ligado ran short of money, and Inmarsat tried to make sure it collected as much as possible.</p>
<p>The agreement was great for Inmarsat (which received ~$1.7B in spectrum lease payments, while its new owner, Viasat, stands to receive billions more between now and 2107) and Rupert Pearce, then General Counsel of Inmarsat, who negotiated the agreement and subsequently moved on to become CEO of Inmarsat. MSV&#8217;s then CEO Alex Good signed the agreement because Falcone had told him that an agreement was needed before Harbinger would provide a sorely needed $500M cash infusion (and Falcone had no understanding of what it actually said). Of course Falcone had many regrets later on, when LightSquared was forced into bankruptcy by GPS interference concerns, and once it became clear that Ligado was not going to deliver a windfall from its spectrum holdings, he <a href="https://law.justia.com/cases/new-york/appellate-division-first-department/2025/index-no-652342-20-appeal-no-3904-3905-3906-case-no-2023-03932-2023-04134-2023-04135.html">unsuccessfully sued MSV&#8217;s executives and owners</a>.</p>
<p>That brings us to today, when the dispute flared up once again, and both Viasat and Ligado filed competing motions with the bankruptcy court, detailing a dispute over the agreement to assume the Cooperation Agreement and sublease the spectrum to AST. There was a contentious mediation which had appeared to be <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/8376c83d-0414-4a52-9c69-0ac88b979cd6_651.pdf">settled back in June</a>.</p>
<p>Now <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/a7c7ea3c-014f-4e4d-9695-610b7d617f6e_827.pdf">Ligado alleges</a> that the Cooperation Agreement does not prohibit either Ligado or AST from seeking access to more L-band spectrum outside the US in the future, while <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/8b3bff54-6efd-421c-8fdf-a0b75f0c5795_825.pdf">Viasat alleges</a> that the Cooperation Agreement has always prevented Ligado from operating outside the US, and AST should also be bound by these terms.</p>
<p>Ligado cites the <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/b5775799-98be-4e66-a1b6-0aa0e938979d_831.pdf">drafting of the Mediation Agreement</a> to support its argument that the only limitation is on AST&#8217;s initial application for its LEO constellation and nothing stops it from making modification requests in the future. It also includes a <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/e27fe368-6057-4baf-a0d5-24859cde12a5_828.pdf">curious declaration from CEO Doug Smith</a>, which sets out Ligado&#8217;s attempts to do a satellite lease deal with Avanti in 2016, at a time when there was <a href="https://tmfassociates.com/blog/2016/12/08/chinese-checkers/">lots of intrigue around Avanti&#8217;s future</a>.</p>
<p>On the other hand Viasat argues that the Cooperation Agreement contains multiple references to Inmarsat&#8217;s exclusivity outside the US, and that the company would never have agreed to a deal that left Ligado or AST with the potential to interfere with its operations elsewhere in the world. Of course, Viasat has its own <a href="https://www.viasat.com/news/latest-news/corporate/2025/space42-and-viasat-announce-partnership-to-explore-shared-global/">ambitions to build a LEO D2D constellation</a> in partnership with Space42, operating in the L-band around the world, plus the 2GHz MSS band in Europe.</p>
<p>It remains unclear what the outcome of this dispute will be, especially as US bankruptcy courts often tend to favor the debtor in disagreements with creditors, but this could hold up the proceedings for quite a while. That may be one of Viasat&#8217;s objectives, as it looks towards an EU decision on 2GHz by the end of the year, and tries to cement its own LEO funding plans. <a href="https://casedocs.omniagentsolutions.com/cmsvol2/pub_47388/a7c7ea3c-014f-4e4d-9695-610b7d617f6e_827.pdf">Ligado&#8217;s submission</a> even states explicitly that &#8220;Inmarsat&#8217;s position poses an existential threat both to the viability of the AST Transaction and the feasibility of the [Bankruptcy Reorganization] Plan&#8221;.</p>
<p>It is also intriguing why AST is so keen to pursue L-band rights outside the US, especially as these will undoubtedly be very difficult to secure, given the longstanding presence of both Viasat/Inmarsat and Space42/Thuraya. However, an application by Viasat to shift spectrum from GEO to LEO could provide an opening and AST would certainly prefer it if Viasat didn&#8217;t build another competing LEO NTN/D2D constellation.</p>
<p>But I also suspect that AST realizes the weakness of its claim to 2GHz (where the company claimed to have &#8220;priority rights&#8221; from <a href="https://tmfassociates.com/blog/2025/08/06/dont-mention-the-satellite-delays/">last week&#8217;s deal with Sky and Space Global</a>, omitting to mention that these are <em>low</em> priority) and the not insignificant probability that it will lose the EU 2GHz competition to either SES/Lynk or EchoStar (most observers think Viasat is fairly certain to retain its rights and there is only expected to be one other wideband license up for grabs). This would mean AST has little option other than to pursue L-band rights on a global basis if it wants to build a new constellation operating in &#8220;midband&#8221; spectrum in a few years time.</p>
<p>Now we wait to see how this develops. But for the time being AST may no longer be able to claim a clear path to developing what it asserts will be &#8220;broadband&#8221; D2D through use of MSS spectrum. So while this dispute continues, the company will have to focus on its very limited terrestrial spectrum leases with AT&#038;T and Verizon, which will at best be sufficient to offer a narrowband service that is similar to Starlink (and will need the FCC to approve AST&#8217;s non-compliant SCS application, which is not at all certain).</p>
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		<title>Don&#8217;t mention the satellite delays&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/08/06/dont-mention-the-satellite-delays/</link>
		<comments>https://tmfassociates.com/blog/2025/08/06/dont-mention-the-satellite-delays/#comments</comments>
		<pubDate>Wed, 06 Aug 2025 23:51:24 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AST SpaceMobile]]></category>
		<category><![CDATA[Echostar]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[Spectrum]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6751</guid>
		<description><![CDATA[AST is clearly frantic to talk about anything other than the &#8220;developmental delays&#8221; which are holding up shipment of the FM1 satellite to India and have caused the launch to be pushed back to late fall, despite some employees apparently taking the trouble to go public about the company&#8217;s satellite manufacturing tribulations. So that helps [...]]]></description>
			<content:encoded><![CDATA[<p>AST is clearly frantic to talk about anything other than the &#8220;<a href="https://www.thehindu.com/sci-tech/science/after-nisar-isro-gearing-up-for-next-us-collaboration-with-bluebird-communications-satellite-launch/article69882412.ece/amp/">developmental delays</a>&#8221; which are holding up shipment of the FM1 satellite to India and have caused the launch to be pushed back to late fall, despite some employees apparently taking the trouble to go public about the company&#8217;s <a href="https://x.com/philliplyle410/status/1950965860203635133">satellite manufacturing tribulations</a>.</p>
<p>So that helps to explain the bizarre <a href="https://www.businesswire.com/news/home/20250806333130/en/AST-SpaceMobile-Announces-Agreement-to-Acquire-Global-S-Band-Spectrum-Priority-Rights-Held-under-the-International-Telecommunication-Union">announcement today</a> that AST has an &#8220;Agreement to Acquire Global S-Band Spectrum Priority Rights Held under the International Telecommunication Union&#8221;. AST clearly didn&#8217;t want anyone to look to closely at this spectrum deal, because they simply refer to acquiring an unnamed &#8220;entity&#8221;, and the press release is disingenuously worded to <a href="https://x.com/DefinitionsNew/status/1953107796167409804">convince the company&#8217;s clueless cult of investors</a> that AST will have priority over &#8220;up to an additional 60 MHz of mid-band satellite spectrum&#8221;.</p>
<p>It doesn&#8217;t <a href="https://x.com/TMFAssociates/status/1953066155591000537">take</a> <a href="https://x.com/TMFAssociates/status/1953067269774557450">much</a> effort to identify the entity concerned, which is Sky and Space Global (SSG), as multiple people have confirmed to me today. SSG made a failed attempt to enter the MSS market almost a decade ago, after <a href="https://announcements.asx.com.au/asxpdf/20170327/pdf/43h22tl7j8tg9p.pdf?platform=hootsuite">going public in Australia</a>, hyping up its &#8220;unique expertise in space technology&#8221; that was &#8220;set to revolutionize the existing satellite communications industry with its price disruptive first mover technology&#8221; and &#8220;bring affordable coverage to billions of the world&#8217;s most unserved people&#8221;. AST&#8217;s original business plan (which involved a <a href="https://patents.google.com/patent/US9973266B1/ko">large number of nano-satellites</a> and was intended to start with an equatorial constellation) could almost have been taken straight from the SSG pitch.</p>
<p>SSG only launched 3 satellites back in 2017, which de-orbited in spring 2023, though the filing was <a href="https://www.itu.int/net/ITU-R/space/snl/list1149/index.asp?sel_satname=&#038;sel_orbit_from=&#038;sel_orbit_to=&#038;sel_adm=&#038;sel_org=&#038;sel_suspension_from=&#038;sel_suspension_to=&#038;sel_resumption_from=&#038;sel_resumption_to=&#038;sel_sns_id=&#038;sel_resumption_yes=&#038;sel_resumption_no=&#038;mod=asc&#038;order=long_nom">brought back into use</a> by one of the satellites launched on the Jan 14 Falcon 9 Transporter-12 rideshare. But what AST&#8217;s language is trying to obscure is that SSG&#8217;s ITU filings have lower priority than both EchoStar and Omnispace, and also describe a system which is completely incompatible with AST&#8217;s recent application to the FCC.</p>
<p>AST is now planning 248 satellites of which 220 will be at 53 degrees inclination and the remaining 28 in sun synchronous orbit, having abandoned its original plan for an equatorial constellation. However, SSG (whose filing is named SSG-CSL in the ITU database) has filed for only 3 test satellites in sun synchronous orbit and the remaining 360 satellites in near equatorial orbits (0, 10 and 13 degrees inclination). So even if AST adjusted its orbit plan to conform with SSG&#8217;s filings, it would then be useless for serving high value markets in Central and North America, Europe, the Middle East and Asia.</p>
<p>That&#8217;s why it isn&#8217;t surprising that SSG&#8217;s licenses are so cheap, compared with EchoStar and Omnispace, and why by choosing to acquire SSG rather than say Omnispace, it is clear that AST is more interesting in gaining favorable PR (from people who either <a href="https://x.com/CatSE___ApeX___/status/1953219254062289143">don&#8217;t understand</a> or would prefer to lie about how <a href="https://x.com/CatSE___ApeX___/status/1953215013717520837">spectrum rights</a> work) than actually providing service using this filing. Just don&#8217;t ask when (if ever) AST will actually launch a constellation.</p>
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		<title>Everything you wanted to know about D2D but were afraid to ask&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/08/02/everything-you-wanted-to-know-about-d2d-but-were-afraid-to-ask/</link>
		<comments>https://tmfassociates.com/blog/2025/08/02/everything-you-wanted-to-know-about-d2d-but-were-afraid-to-ask/#comments</comments>
		<pubDate>Sat, 02 Aug 2025 17:36:35 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AST SpaceMobile]]></category>
		<category><![CDATA[Echostar]]></category>
		<category><![CDATA[Handheld]]></category>
		<category><![CDATA[Lynk]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[Services]]></category>
		<category><![CDATA[SES]]></category>
		<category><![CDATA[SpaceX]]></category>
		<category><![CDATA[Spectrum]]></category>
		<category><![CDATA[ViaSat]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6729</guid>
		<description><![CDATA[Yesterday EchoStar chose to announce its plans for a new $5B D2D constellation of 200 satellites, including an initial US$1.3B contract with MDA to build the first 100 satellites. Though the MDA contract was in line with my prediction back in March, EchoStar&#8217;s heavy emphasis on prospective wholesale partnerships with mobile operators during the results [...]]]></description>
			<content:encoded><![CDATA[<p>Yesterday EchoStar chose to announce its plans for a new $5B D2D constellation of 200 satellites, including an <a href="https://www.prnewswire.com/news-releases/mda-space-selected-by-echostar-for-worlds-first-open-ran-d2d-leo-constellation-302519551.html">initial US$1.3B contract with MDA to build the first 100 satellites</a>. Though the MDA contract was in line with <a href="https://x.com/TMFAssociates/status/1899275351231979532">my prediction back in March</a>, EchoStar&#8217;s heavy emphasis on prospective wholesale partnerships with mobile operators during the results call suggests that Apple has declined to provide financial backing for the system. That&#8217;s perhaps unsurprising after the <a href="https://www.theinformation.com/articles/apples-satellite-ambitions-threatened-elon-musk-internal-resistance">press revelations in May</a> describing a lack of consensus within Apple about whether to continue investing in D2D.</p>
<p>As EchoStar CEO Akhavan noted in the results call, EchoStar had to make a decision now, because the EU is in the process of deciding what to do about the current European 2GHz licenses held by EchoStar and Viasat when they expire in spring 2027. Indeed I understand that EchoStar assured the EU of its plans to build this system in its confidential <a href="https://digital-strategy.ec.europa.eu/en/news/commission-requests-input-stakeholders-use-spectrum-bands-mobile-satellite-systems">response to the EU&#8217;s consultation back on June 30</a>. Now we face an all-out battle between at least four players (Viasat, EchoStar, AST/Vodafone and SES/Lynk) for only two licenses when they are awarded at the end of this year.</p>
<p>However, EchoStar&#8217;s announcement also came as an unwelcome surprise to many investors, who were hoping that <a href="https://www.bloomberg.com/news/articles/2025-07-30/echostar-urged-by-us-to-sell-spectrum-to-settle-squatting-claim">reports earlier in the week</a> of FCC Chairman Carr&#8217;s &#8220;Best and Final Offer&#8221; to sell AWS-4 spectrum signaled that EchoStar would scale back its ambitions and strike a deal to sell or lease this spectrum. Contrary to some analyst perceptions, the biggest threat from the FCC has always been a potential rulemaking on the 2GHz MSS band that would open it up to additional sharing by Starlink. However, it was also very unlikely that Elon Musk and Charlie Ergen would have a meeting of minds on the value of this spectrum in any commercial deal for Starlink to access the band.</p>
<p>So its now clear that Ergen has decided to defy Carr&#8217;s mandate and move forward on his own, without providing any evidence that a major new partner for the system has been secured. Hopefully clarity on financing and partnerships will be provided in September when EchoStar has promised to give more details of its plans. But in the meantime, Carr must decide whether to launch a 2GHz rulemaking or leave Starlink out in the cold without access to MSS spectrum that will soon be sorely needed to increase the capacity of its D2D system. Carr&#8217;s decision may well turn on whether Ergen has secured President Trump&#8217;s backing, after his recent falling out with Elon Musk, and that would certainly help to explain why EchoStar is highlighting a large headline investment of $5B in the planned D2D system.</p>
<p>Fortuitously for those who are trying to make sense of these developments, yesterday evening I also released my <a href="https://tmfassociates.com/blog/wp-content/uploads/2025/08/D2D-order-form-and-contents-Aug-2025.pdf">new 100+ page deep dive report on D2D</a>, telling you everything you need to know about D2D technology, regulation and the progress of all the different satellite operators involved in this market, updated with the latest information on EchoStar, AST, Starlink, Apple/Globalstar and other planned systems. We&#8217;ve seen lots of <a href="https://www.analysysmason.com/contentassets/0073eb3b7b00483e95dfbf2331707371/analysys_mason_mnos_oems_satellite_d2d_jun2025_nsi139.pdf">ludicrous forecasts about the size of this market</a>, which simply fail to understand the <a href="https://wia.org/satellite-d2d-and-terrestrial/">technological constraints on these services</a> in terms of capacity, data rates and costs. Unlike these other forecasts, my analysis looks at realistic capacity, usage and pricing models to assess how many customers Starlink and AST&#8217;s systems can serve and what they will need to charge per Gbyte of capacity. That&#8217;s a familiar topic to who followed my blog posts on LightSquared back in 2011-12 when it became clear that <a href="https://tmfassociates.com/blog/2011/12/07/theres-no-there-there/">there was no there there&#8230;</a></p>
<p>I also analyze regulatory constraints, feasible deployment schedules (especially in light of <a href="https://www.thehindu.com/sci-tech/science/after-nisar-isro-gearing-up-for-next-us-collaboration-with-bluebird-communications-satellite-launch/article69882412.ece/amp/">continuing delays for AST</a> which make the company&#8217;s claimed launch plans totally implausible) and how much spectrum will be needed for these systems to operate. As I discussed in another <a href="https://summitridgegroup.com/spectrum-for-direct-to-device-operators/">report back in January</a>, MSS spectrum (and the 2GHz band in particular) is likely to be critical to providing adequate capacity for D2D constellations. Starlink only has a paired 5MHz block of spectrum in the US, but has already decided that it needed to <a href="https://fccprod.servicenowservices.com/sys_attachment.do?sys_id=795299691b4b2e1084ab85d6624bcb1b">upgrade to a paired 15MHz block in New Zealand</a> after only 6 months of operations. So EchoStar&#8217;s announcement, and how the FCC now decides to respond, will be critical in determining the future direction of this market.</p>
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		<title>How to annoy the FCC&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/07/25/how-to-annoy-the-fcc/</link>
		<comments>https://tmfassociates.com/blog/2025/07/25/how-to-annoy-the-fcc/#comments</comments>
		<pubDate>Fri, 25 Jul 2025 16:58:00 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[AST SpaceMobile]]></category>
		<category><![CDATA[AT&T]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[T-Mobile]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6698</guid>
		<description><![CDATA[It&#8217;s been obvious for a long time that the quality of AST&#8217;s regulatory submissions has been poor, which has led to considerable delays in gaining FCC approval, as was evident when it took more than four years from the time AST&#8217;s initial petition for market access was submitted in April 2020 before approval was granted [...]]]></description>
			<content:encoded><![CDATA[<p>It&#8217;s been obvious for a long time that the quality of AST&#8217;s regulatory submissions has been poor, which has led to considerable delays in gaining FCC approval, as was evident when it took more than four years from the time AST&#8217;s initial petition for market access was <a href="https://fccprod.servicenowservices.com/sys_attachment.do?sys_id=5a8ff81a879aa610b986a7570cbb3571">submitted in April 2020</a> before approval was <a href="https://docs.fcc.gov/public/attachments/DA-24-756A1_Rcd.pdf">granted in August 2024</a> for launch of five BlueBird-1 satellites. I heard complaints on more than one occasion that more professionalism was needed from AST, with contrasts drawn to the high quality and intense focus of SpaceX&#8217;s regulatory team working on SCS. And the company seemed to have acknowledged this concern by <a href="https://x.com/TMFAssociates/status/1927387563431465303">hiring Jennifer Manner in May 2025</a>.</p>
<p>But over the last month, AST and its partner AT&#038;T have taken it upon themselves to go to a whole new level in causing annoyance to FCC staff. <a href="https://apps.fcc.gov/els/GetAtt.html?id=379517&#038;x=">On July 1</a>, AST &#8220;urge[d] the Commission to approve the [FM1] Application by July 11 to allow safe shipment of FM1 for its scheduled August launch on time. Failure to do so will place our ability to launch in August at significant risk.&#8221; The irritation of FCC staff was clear in a <a href="https://apps.fcc.gov/els/GetAtt.html?id=379575&#038;x=">July 2 email</a> noting that &#8220;due to substantial changes in the technical parameters of your S-band request, we will need to coordinate new spot frequencies with NTIA. This will restart the coordination timeline with NTIA&#8221;. Nevertheless, the NTIA and FCC pushed this through and <a href="https://apps.fcc.gov/els/GetAtt.html?id=380200&#038;x=">granted the FM1 approval on July 11</a> as requested. But then AST didn&#8217;t ship the FM1 satellite the next day, and <a href="https://x.com/Pivotal_Capital/status/1948738035106873717">has now revealed</a> that in fact the satellite won&#8217;t be shipped to India until August. So why did the FCC and NTIA have to put in all that work over the July 4 holiday?</p>
<p>AT&#038;T&#8217;s actions this week have been even more egregious, with an <a href="https://about.att.com/pages/satellite.html">announcement on July 23</a> (timed to try and counter <a href="https://www.t-mobile.com/coverage/satellite-phone-service">T-Mobile&#8217;s launch of Starlink D2D satellite service</a> that day) stating that &#8220;On Monday, July 21, AT&#038;T and AST SpaceMobile successfully completed the first-ever native voice call (VoLTE) and text (SMS) made directly through AST&#8217;s Block 1 satellites with a standard cell phone using AT&#038;T spectrum and passing through the AT&#038;T core network.&#8221; But <a href="https://apps.fcc.gov/els/GetAtt.html?id=367035&#038;x=">AST&#8217;s license for testing with AT&#038;T</a> expired on May 30 and the <a href="https://apps.fcc.gov/els/GetAtt.html?id=376036&#038;x=">request for renewal</a> has not yet been granted. So if AT&#038;T did conduct a &#8220;call and text [which] utilized AT&#038;T&#8217;s spectrum and commercial network&#8221; on July 21, that was clearly outside the licensed testing period.</p>
<p>As an aside, it&#8217;s also worth noting that AT&#038;T has now pulled back on prior claims that AST <em>will</em> support broadband data services including video calls, modifying <a href="https://about.att.com/pages/satellite.html">the website</a> from <a href="https://web.archive.org/web/20250701094724/https://about.att.com/pages/satellite.html">the original version</a> to indicate only that &#8220;One day [the satellite service] <em>may</em> also support video services&#8221;. AT&#038;T also shifted from claiming that &#8220;Our customers will have access to a satellite-based cellular network with a standard smartphone – no special device is needed&#8221; to indicating that &#8220;More information on eligible devices and service requirements will be shared closer to launch&#8221;.</p>
<p><a href="http://tmfassociates.com/blog/wp-content/uploads/2025/07/ATT-satellite-July-1.png"><img src="http://tmfassociates.com/blog/wp-content/uploads/2025/07/ATT-satellite-July-1-300x126.png" alt="" title="AT&amp;T website on July 1" width="300" height="126" class="aligncenter size-medium wp-image-6706" /></a></p>
<p><a href="http://tmfassociates.com/blog/wp-content/uploads/2025/07/ATT-satellite-July-24.png"><img src="http://tmfassociates.com/blog/wp-content/uploads/2025/07/ATT-satellite-July-24-300x180.png" alt="" title="AT&amp;T&#039;s website as of July 24" width="300" height="180" class="aligncenter size-medium wp-image-6707" /></a></p>
<p>One potential reason for the delay in the FCC renewing AST&#8217;s applications for continued testing is that AST has also simply ignored the conditions of its test licenses, which required the company to &#8220;submit a test report in the ELS license file for this grant within 150 days reporting on activities occurring during the first 90 days of the license&#8221;. So for the AT&#038;T testing license granted on January 23 (the grant letter erroneously says 2024 but it was actually granted on January 23, 2025), the initial test report would have been due by no later than June 22. However, to date, no test reports have been filed for any of AST&#8217;s BlueBird-1 experimental license grants.</p>
<p>The FCC has been accommodating of AST&#8217;s regulatory failings to date, and put the company&#8217;s June 2025 modification submission <a href="https://docs.fcc.gov/public/attachments/DA-25-532A1.pdf">on public notice</a> with regard to the feeder links and TT&#038;C. That might even allow for approval of satellite launches later this year if the recent <a href="https://fccprod.servicenowservices.com/sys_attachment.do?sys_id=ceb2498a877e2a109f0cc8460cbb3508 ">submission of an SCS agreement with FirstNet</a> is deemed compliant. But before getting to that point, the FCC will also need to decide whether to overlook AST and AT&#038;T&#8217;s recent violations of AST&#8217;s experimental license conditions.</p>
<p>EDIT (7/25): Well it seems like I ruined somebody&#8217;s Friday evening dinner plans, because a few hours after this post was published, AST submitted the <a href="https://apps.fcc.gov/els/GetAtt.html?id=381471&#038;x=">delinquent 90 day test report</a> for its experimental testing with AT&#038;T and Verizon. Presumably the other missing test reports for the UK and Turkey will be filed soon as well.</p>
<p>EDIT (7/26): If the FCC was mildly annoyed with AST&#8217;s incompetence before, they must now be completely furious after AST <a href="https://fccprod.servicenowservices.com//sys_attachment.do?sys_id=3599e8981b072a10eb9364eae54bcb8e">submitted a new letter on Friday evening</a>, characterized as a response to the Space Bureau&#8217;s request for additional information. And I can only conclude that the company&#8217;s engineers are total idiots. This letter completely contradicts itself, with the answer to question 1 stating that FM1-FM23 &#8220;will be deorbited from 520km through atmospheric drag&#8221; while AST&#8217;s &#8220;additional clarification&#8221; at the end indicates that after FM1 and FM2 (which is now clearly intended to be launched on a dedicated Falcon 9 rocket at huge cost), of the &#8220;up to 20 satellites&#8221; that AST &#8220;anticipates launching&#8230;through the end of this year&#8230;the remaining 18 satellites will operate at an altitude of 690km&#8221;.</p>
<p>And if this &#8220;additional clarification&#8221; is taken at face value, then the current public notice and comment period has just been invalidated, since the comments received on July 21 were based on AST&#8217;s June 12 submission, which claimed that FM1-FM23 would orbit at 520km and that these satellites would only carry 20kg of fuel. I&#8217;m left wondering if the paragraph on &#8220;planned upcoming satellite launches&#8221; was simply inserted by company management at the last minute to try and pump up the share price, and no one checked for compatibility with the rest of the document or AST&#8217;s prior submissions.</p>
<p>Of course if FM3-FM23 were at 690km then that&#8217;s not compatible with AST&#8217;s claim today (in response to question 5) that &#8220;The nominal deorbit plan is powered deorbit to below 530km&#8221;. And incidentally it also makes no sense for AST to suggest in response to question 4 that &#8220;During the disposal phase, the spacecraft will randomly tumble due to its shape and mass distribution throughout its descent, except for collision avoidance maneuvers during which the spacecraft will operate with an edge-on orientation&#8221; when AST indicates in question 1 that only &#8220;approximately 1kg of Xenon will remain available on FM1-FM23 for collision avoidance maneuvers throughout the mission-life and post-mission phases&#8221; since that&#8217;s certainly not going to be sufficient to stabilize such a huge spacecraft within a few hours <em>and</em> perform collision avoidance. Is AST instead suggesting that after FM2 it will move straight to launching FM24 and defer FM3-FM23 until later? Or is AST intending to use direct injection to 690km? It&#8217;s impossible to tell&#8230;</p>
<p>This continues AST&#8217;s prior incompetence in engineering submissions that was so evident during the review of FM1, when the <a href="https://apps.fcc.gov/els/GetAtt.html?id=376295&#038;x=">company claimed</a> that the mass in the Orbital Debris Assessment Report didn&#8217;t add up because of “quantity errors in the input” and “omissions” of various components. Then AST just added in suspiciously round numbers of 5000 fasteners (each weighing exactly 10g) and 100 brackets (each weighing exactly 500g) and still couldn&#8217;t make the mass of the phased array on FM1 and FM2 add up to 2863kg (an error of 117kg which has been carried over to the June 12 modification application).</p>
<p>It&#8217;s now hard to see how anyone can prepare reply comments based on this new nonsensical AST submission. So unless and until these issues are clarified, I suspect the FCC will either have to extend the reply timeline or even restart the whole process from scratch.</p>
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		<title>The fight over BEAD funding for satellite</title>
		<link>https://tmfassociates.com/blog/2025/07/23/the-fight-over-bead-funding-for-satellite/</link>
		<comments>https://tmfassociates.com/blog/2025/07/23/the-fight-over-bead-funding-for-satellite/#comments</comments>
		<pubDate>Wed, 23 Jul 2025 20:12:18 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[Broadband]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[Services]]></category>
		<category><![CDATA[SpaceX]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6684</guid>
		<description><![CDATA[Last week, the Washington Post published an article about Starlink&#8217;s supposed capacity limitations, based on a paper from X-Lab. This is part of the larger fight over the future of BEAD funding and how much should be redirected from fiber to satellite, with a rival ITIF paper suggesting the opposite, that it&#8217;s a myth that [...]]]></description>
			<content:encoded><![CDATA[<p>Last week, the <a href="https://www.washingtonpost.com/technology/2025/07/18/starlink-internet-satellite-speed-elon-musk/">Washington Post published an article</a> about Starlink&#8217;s supposed capacity limitations, based on a <a href="https://thexlab.org/wp-content/uploads/2025/07/Starlink_Analysis_Working_Paper_v0.2.pdf">paper from X-Lab</a>. This is part of the larger fight over the future of BEAD funding and how much should be redirected from fiber to satellite, with a rival ITIF paper suggesting the opposite, that <a href="https://itif.org/publications/2025/07/14/broadband-myths-leos-dont-belong-in-bead/">it&#8217;s a myth that &#8220;LEOs Don’t Belong in BEAD&#8221;</a>.</p>
<p>SpaceX has also been lobbying hard on this topic, <a href="https://www.starlink.com/updates/network-update">publishing a network update</a> that notes speeds and latency have both been improving in the US, even with more than 2M active users, and regulatory chief Dave Goldman <a href="https://x.com/davesgoldman/status/1946260328569827795">highlighting his conversations</a> with the FCC, NTIA and others &#8220;about how Starlink will make gigabit speeds available to people across the country&#8221;. Countering that, <a href="https://www.yahoo.com/news/elon-now-facing-possibility-spacex-171323045.html">several</a> <a href="https://nymag.com/intelligencer/article/elon-musk-spacex-starship-doomed.html">articles</a> have been published suggesting that Starship might never succeed, which would mean SpaceX being unable to launch the larger V3 satellites that the company is &#8220;targeting to begin launching&#8230;in the first half of 2026&#8243;</p>
<p>As one might expect, the lobbyists take an extreme position and the reality is somewhere in the middle: fundamentally there must be some limit to how much it is worth spending on fiber deployment to the most rural and remote locations, when Starlink (and in the future hopefully Kuiper) can provide an high quality, cost-effective residential broadband service. But on the other hand, putting fiber in the ground is a long term investment and it is comparing apples and oranges to equate that to the cost of a Starlink user terminal that the company expects to have a <a href="https://tmfassociates.com/blog/wp-content/uploads/2025/07/Useful-life.png">useful life of three years</a>.</p>
<p>The X-Lab paper suggests that Starlink shouldn&#8217;t be funded by BEAD in areas where the population density is more than 6.7 Broadband Service Locations (BSLs) per square mile (which corresponds to limiting the addressable market to just over 3M homes around the country). However, when Starlink had waitlists in parts of the US such as the Pacific Northwest in January this year (since replaced by &#8220;congestion charges&#8221;), these were in regions with an average of about 4-5 <em>customers</em> per square mile, based on Starlink&#8217;s estimated US subscriber base in the area deemed &#8220;sold out&#8221;.</p>
<p><a href="http://tmfassociates.com/blog/wp-content/uploads/2025/07/Waitlists-Jan-2025.png"><img src="http://tmfassociates.com/blog/wp-content/uploads/2025/07/Waitlists-Jan-2025-217x300.png" alt="" title="Waitlists Jan 2025" width="217" height="300" class="aligncenter size-medium wp-image-6686" /></a></p>
<p>Since not all households would be expected to actually subscribe to internet service, this suggests that Starlink has already seen plenty of demand in areas at or above the proposed 6.7 BSL per square mile density limit, and those customers certainly found it worth paying for, even if the uplink speeds often <a href="https://www.ookla.com/articles/starlink-us-performance-2025">fell short of the BEAD benchmark</a>. Regardless of when/if Starlink actually gets to orbit, even the current Falcon 9 launch tempo is allowing the capacity of the Starlink service to improve significantly over time, so this proposed cutoff seems too low in limiting where Starlink can usefully provide service.</p>
<p>More to the point, the calculations in the paper simply don&#8217;t match the actual constraints on the Starlink service. The assumption is that only one satellite can serve a given cell, but a Starlink user would realize that&#8217;s not how it works in practice because if you set up a portable Starlink terminal and take it down each evening, one day you may be told (by the app) to point it say northeast, and the next day you may be told to point it west. That&#8217;s because the system is load balancing across the multiple satellites serving a given cell.</p>
<p>At the moment, the primary constraint on the downlink is the FCC&#8217;s limit on spectrum re-use (known technically as Nco=1) which means Starlink can only serve a single cell once with a given channel across Starlink&#8217;s 2GHz of downlink spectrum (10.7-12.7GHz). While the efficiency of spectrum use varies (for example it&#8217;s lower for a Starlink mini than a regular terminal), a reasonable estimate is ~3-4bps/Hz. So 2GHz of spectrum would equate to a maximum of ~7Gbps in a cell, which isn&#8217;t too different to the 6Gbps assumed in the paper. However, the FCC has allowed Starlink&#8217;s Gen1 and Gen2 satellites to be counted separately for the purposes of the re-use limit, and so the current theoretical maximum downlink speed in a cell is actually twice this level. And now the FCC is consulting on <a href="https://docs.fcc.gov/public/attachments/FCC-25-23A1.pdf">loosening these limits further</a>.</p>
<p>The X-Lab paper focuses more on the uplink capacity as the key density constraint and it is certainly the case that the amount of spectrum available to Starlink is more limited there, because only 500MHz of Ku-band spectrum is allocated to uplink (14.0-14.5GHz) compared to 2GHz for downlink. However, the primary determinant of uplink capacity for Starlink end users is the number of timeslots allocated to uplink transmission, because the network uses Time Division Duplex (TDD) and was originally only configured to support transmission <a href="https://wccftech.com/spacex-receives-fcc-approval-that-can-increase-starlink-network-speeds-significantly/">up to 10% of the time</a>. That was intended to ensure that the terminal cannot produce enough radiation to heat up the head of someone standing in front of it (what the FCC refers to as SAR limits). Over time SpaceX has been able to improve this percentage (<a href="https://wccftech.com/new-starlink-dishes-for-cars-planes-to-carry-radiation-hazard-warning/">now 15.5% of the time for uncontrolled use</a>) and professionally installed terminals can go even higher. So there&#8217;s no reason to conclude that the supposed 0.4Gbps per beam assumed in the paper is a hard limit.</p>
<p>On the other side of the lobbying effort, the ITIF paper ignores the fact that the BEAD funding mechanisms are extremely poorly suited to fund satellite deployments, as I discussed in <a href="https://x.com/TMFAssociates/status/1945536444380106933">this thread on X/Twitter</a>. BEAD has been set up so you bid for money to deploy infrastructure in a particular geographical area, <em>regardless of how many customers actually sign up</em>. That makes sense when funding fiber or even wireless infrastructure: if you build a tower or lay a fiber line, the only way to make a return is to sell service within that coverage area. However, if you fund a satellite operator to build more LEO satellites, then those satellites will spend only a tiny fraction of 1% of the time over that area as they go around the Earth, and can devote 99%+ of the orbit to earning money from more valuable customers. So there is no real incentive for a satellite operator to actually sell service to the unserved customers.</p>
<p>The best way to square this circle would be to provide <em>affordability</em> instead of deployment incentives (i.e. a subsidy for terminals and/or monthly service), so that the satellite operator only earns money when end users in these unserved areas actually sign up, which was how the Affordable Connectivity Program (ACP) was structured. Otherwise the satellite operator is getting paid for something they are already doing: Starlink has over 7000 satellites in orbit already and is launching dozens every week, why pay them to launch a few hundred more? One possibility is <a href="https://www.benton.org/blog/what-do-we-know-about-leo-bead-bids">to structure reimbursement payments</a> &#8220;based on the number of subscribers the provider serves and/or enrolls&#8221; rather than &#8220;in equal installments throughout the period of performance&#8221;.</p>
<p>And when it comes to bidding, why wouldn&#8217;t any satellite operator bid a very low amount for the right to deploy service in unserved areas? If they can prevent terrestrial broadband technologies like fiber and wireless from getting subsidies for deployment, then they have a captive market to themselves. Certainly if both Starlink and Kuiper are bidding against one another, and these reimbursements are independent of the number of customers served, it would be logical for their deployment bids to be particularly low, since the cost of simply making service available is essentially zero. We saw in the RDOF auction (when Starlink didn&#8217;t face any meaningful competition from other satellite operators) that SpaceX was able to undercut terrestrial technologies, but the fight over whether or not they actually were going to receive their <a href="https://www.fierce-network.com/telecom/fcc-upholds-rejection-starlinks-885m-rdof-subsidy">$885M in winning bids</a>, made absolutely no difference to the number of satellites that the company put into orbit.</p>
<p>So in conclusion, satellite has a great opportunity to enhance broadband service in rural areas, potentially in more places than the very lowest density parts of the country. But unless the BEAD payments are linked to the number of customers served, the program will not do a good job of helping consumers realize those benefits.</p>
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		<title>Back to blogging&#8230;</title>
		<link>https://tmfassociates.com/blog/2025/07/06/back-to-blogging/</link>
		<comments>https://tmfassociates.com/blog/2025/07/06/back-to-blogging/#comments</comments>
		<pubDate>Sun, 06 Jul 2025 21:05:36 +0000</pubDate>
		<dc:creator>timfarrar</dc:creator>
				<category><![CDATA[Echostar]]></category>
		<category><![CDATA[Financials]]></category>
		<category><![CDATA[Operators]]></category>
		<category><![CDATA[Regulatory]]></category>
		<category><![CDATA[SpaceX]]></category>
		<category><![CDATA[Spectrum]]></category>

		<guid isPermaLink="false">http://tmfassociates.com/blog/?p=6635</guid>
		<description><![CDATA[After focusing my public posts mainly on Twitter/X threads for the past couple of years, I thought it would be better to resume blogging, especially as it&#8217;s got harder and harder to search X posts effectively. I&#8217;ve also been publishing numerous research publications, which included a detailed report on the IFC market last summer, an [...]]]></description>
			<content:encoded><![CDATA[<p>After focusing my public posts mainly on Twitter/X threads for the past couple of years, I thought it would be better to resume blogging, especially as it&#8217;s got harder and harder to search X posts effectively. I&#8217;ve also been publishing numerous research publications, which included a <a href="https://tmfassociates.com/blog/wp-content/uploads/2024/07/IFC-order-form-and-contents-Jul-2024.pdf">detailed report on the IFC market last summer</a>, an <a href="https://tmfassociates.com/blog/wp-content/uploads/2024/10/Starlink-order-form-and-contents-2024.pdf">updated profile and revenue forecasts for Starlink in October 2024</a>, and a <a href="https://tmfassociates.com/blog/wp-content/uploads/2025/05/LEO-order-form-and-contents-2025.pdf">new report projecting demand for satellite capacity in May 2025</a> that gives a full breakdown between LEO and GEO out to 2033 across the key professional verticals (maritime, aviation, backhaul, enterprise and government). Unlike some other industry forecasts, we are happy to share full details of our spreadsheets containing the historical base data, forecasting methodology and assumptions. One major satellite operator told us, &#8220;your assumptions (especially on the GEO outlook) differ from Novaspace&#8217;s, which is a bit more optimistic about the future of GEO (for now). And I tend to agree with your assessment/assumptions.&#8221;</p>
<p><a href="http://tmfassociates.com/blog/wp-content/uploads/2025/07/LEO-broadband-projections.jpg"><img src="http://tmfassociates.com/blog/wp-content/uploads/2025/07/LEO-broadband-projections.jpg" alt="" title="LEO broadband projections" width="540" height="359" class="aligncenter size-full wp-image-6637" /></a></p>
<p>And due to increased interest in the sector from investors, and the rapid pace of announcements, particularly in D2D, the research service now includes regular (approximately monthly) updates in response to key developments in the industry and takeaways from industry conferences. These include:<br />
A summary of the WSBW conference (Sep 2024)<br />
A note on the Globalstar-Apple deal (Nov 2024)<br />
A briefing on the Globalstar investor day (Dec 2024)<br />
An update on D2D and Starlink (Jan 2025)<br />
A note on Starlink’s C-band filing (Feb 2025)<br />
A summary of developments at Satellite 2025 (Mar 2025)<br />
A review of AST’s technology (Apr 2025)<br />
An update on EchoStar and the FCC (May 2025)<br />
An update on EchoStar and AST (Jun 2025), and<br />
A briefing giving details of Starlink&#8217;s international financials that have never been reported in the press (Jun 2025).</p>
<p>As another subscriber said recently, &#8220;Fascinating, as ever. Thanks for your continued bar-settingly-brilliant analysis.&#8221;</p>
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