March 6, 2025

BY ELECTRONIC FILING
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554

Re: ICFS File No. SAT-PPL-20250214-00047; RM-11975

Dear Ms. Dortch:

The Commission has made clear that it will not accept applications for new mobile-satellite
service (“MSS”) systems in the 1.6/2.4 GHz band without first concluding a proceeding to update
the rules for the band.1 Accordingly, just as it has done for other applications for new systems in
the band, the Commission must also dismiss Globalstar’s premature application to add a new
satellite system—its third—to the band.2 Fortunately, SpaceX’s pending Petition for Rulemaking
to update the sharing rules for the 1.6/2.4 GHz band provides a widely supported vehicle for the
Commission to expeditiously conduct a proceeding to update its rules and then welcome
applications for new systems, such as Globalstar’s C-3 system.3 Dismissing Globalstar’s latest
application and swiftly initiating a rulemaking to update the rules for the band would ensure the
most consistent treatment, efficient sharing, and robust competition between Globalstar and other
next-generation satellite systems—including SpaceX—who have sought to finally make
productive use of this long-fallow spectrum.

The Commission has determined that its nearly two-decade-old rule framework for the
1.6/2.4 GHz band “does not envision an additional CDMA MSS system.”4 Consequently,
“[a]bsent . . . a rulemaking to address any changed circumstances [in the band], . . . the 1.6/2.4
GHz bands are not available for licensing of an additional NGSO MSS system.”5 On this basis,
the Commission has dismissed, without prejudice, U.S. space station applications from next-
generation satellite systems such as SpaceX that have sought to finally make productive use of this
long-fallow spectrum for American consumers.6 It should similarly reject Globalstar’s premature
application for a new system in the band. Affording Globalstar special treatment by accepting its

1
See Space Exploration Holdings, LLC Application for Modification of Authorization for the SpaceX Gen2 NGSO
Satellite System to Add a Mobile-Satellite Service System, ICFS File No. SAT-MOD-20230207-00022, DA 24-
300 ¶ 1 (rel. March 26, 2024) (“Dismissal Order”).
2
See Globalstar Petition for Declaratory Ruling, ICFS File No. SAT-PPL-20250214-00047 (filed Feb. 14, 2025)
(“Globalstar Petition”).
3
SpaceX Petition for Rulemaking, RM-11975 (filed Feb. 21, 2024), available at
https://www.fcc.gov/ecfs/document/102211948918123/1.
4
Dismissal Order ¶ 8.
5
Id.
6
Id.

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Marlene H. Dortch
March 6, 2025
Page 2 of 3

application for an entirely new system in the 1.6/2.4 GHz band would violate the Administrative
Procedure Act by making a substantive rule change without first conducting the rulemaking7 and
arbitrarily and capriciously fail to treat similarly situated parties similarly.8 Accepting Globalstar’s
application for its new, higher-power system in the band would also fundamentally alter the
spectrum environment in the 1.6/2.4 GHz band to the detriment of prospective competitors, such
as SpaceX, whose applications predated Globalstar’s application and who have expressed an
interest in efficiently sharing the band alongside other operators.

Rather than accept Globalstar’s application for yet another system in the 1.6/2.4 GHz band,
the Commission should promptly initiate a rulemaking to modernize the 1.6/2.4 GHz regulatory
framework on the basis of the supportive record generated in response to SpaceX’s Petition for
Rulemaking.9 Doing so would be the fairest and most expeditious route to determine the
appropriate regulatory regime to govern operations in a band that has not been examined in nearly
20 years. As an initial matter, the Bureau has expressly stated that a new rulemaking is not only
the “proper proceeding” to evaluate whether and how the band might accommodate new systems
like Globalstar’s, it is a necessary precondition for accepting such applications.10 Conducting a
rulemaking proceeding would also allow the Commission to develop modern, efficient sharing and
service rules that reflect the monumental advances in technology over the preceding 20 years,
promote rapid deployment, and deliver high-quality, low-latency service that meets consumer
demand. These updated rules will in turn ensure that any new systems in the band—including
Globalstar’s and SpaceX’s new systems—make the most productive, intensive, and efficient use
of this prime mid-band spectrum for American consumers. Fortunately, the 1.6/2.4 GHz band
remains ripe for competition and sharing. As Globalstar itself has noted, over 85% of its spectrum
holdings remain fallow, its U.S.-licensed satellites have dwindled from 29 to just 7 or fewer
satellites, and its operations today use just 0.3% of the capacity of the 1.6/2.4 GHz band.11

As the Commission updates its sharing rules for 1.6/2.4 GHz operations in the United
States, however, it should ensure that U.S.-licensed systems can fairly compete in the band abroad.
Indeed, Globalstar’s application demonstrates that foreign administrations will readily authorize
new systems in the 1.6/2.4 GHz band, even if the United States has declined to do so for domestic
7
5 U.S.C. § 553.
8
Id. § 706.
9
See generally Request for Comment on Petition for Rulemaking by Space Exploration Holdings, LLC, Regarding
Revision of the Commission's 1.6/2.4 GHz "Big LEO" NGSO MSS Sharing Plan, Public Notice, RM-11975, DA
24-298 (rel. Mar. 26, 2024).
10
Dismissal Order ¶ 8.
11
See Application for Modification, ICFS File No. SAT-MOD-20171020-00141, Notification of Reposition at 2
(“[c]urrently seven of Globalstar’s [48] first-generation satellites continue to operate”) (Oct. 31, 2017); In its
recent Form 8-K filing at the Securities and Exchange Commission, Globalstar describes a partnership agreement
with Apple, Inc., that binds it to retain only “15% of network capacity to support its existing and future Duplex,
SPOT and IoT subscribers. See GLOBALSTAR, INC., Quarterly Report (Form 8-K), at Item 7.01 (Sept. 7, 2022),
available at https://investors.globalstar.com/node/14431/html (“Globalstar 8-K”). “This capacity can support an
approximately fifty-fold increase in its own subscriber base following recent and planned investments in the
Company’s space and ground segments.” Id.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com
Marlene H. Dortch
March 6, 2025
Page 3 of 3

operations.12 To facilitate U.S. competitiveness and global leadership in the development of next-
generation satellite technologies and services, the Commission therefore should permit its
licensees to compete internationally in the band by authorizing the deployment of 1.6/2.4 GHz
payloads for global use, with rights to operate in the United States to be determined by the outcome
of the above-referenced rulemaking.

* * *

Globalstar’s application for market access for an entirely new system in the 1.6/2.4 GHz
band must be dismissed, consistent with the precedent set when the Bureau dismissed SpaceX’s
application for a new MSS system for the same reasons. 13 If Globalstar remains interested in
deploying a new MSS system in the 1.6/2.4 GHz band, it will be free to reapply if and when the
Commission revises the MSS sharing framework. As demonstrated above, the time for the
Commission to initiate a proceeding is now, as a rulemaking will ensure that the 1.6/2.4 GHz band
is put to its best, highest, most intensive/efficient use in a robust, competitive MSS ecosystem that
will benefit consumers throughout the United States.

Sincerely,

/s/ Jameson Dempsey

Jameson Dempsey
Director, Satellite Policy

SPACE EXPLORATION TECHNOLOGIES

12
See generally Globalstar Petition.
13
See generally Dismissal Order.

1155 F St NW, Suite 475, Washington, DC 20004 | phone 202.649.2700 | fax 202.649.2701 | spacex.com