The Invisible Battle Above:

How Megaconstellations Are Transforming the Fight for Space's Radio Spectrum

BLUF (Bottom Line Up Front)

The explosive growth of satellite megaconstellations—with over 50,000 satellites projected by 2030—is creating an unprecedented competition for radio frequency spectrum and orbital positions. This scramble involves commercial giants like SpaceX and Amazon, national programs from China and India, and governance challenges for the International Telecommunication Union's decades-old regulatory framework. While these constellations promise to connect billions of offline users, they simultaneously raise critical concerns about spectrum allocation equity, space debris, and whether satellite broadband will bridge or widen the digital divide.

---

The competition unfolding in Earth's orbit today bears little resemblance to the satellite era of even a decade ago. Where hundreds of spacecraft once operated, thousands now crowd low Earth orbit (LEO), with tens of thousands more authorized for launch. This transformation centers not just on the satellites themselves, but on the invisible infrastructure they require: specific bands of radio frequency spectrum and precisely coordinated orbital positions.

The Spectrum Scarcity Problem

Radio spectrum represents a finite natural resource, governed internationally to prevent the chaos of overlapping signals. The International Telecommunication Union (ITU), a United Nations specialized agency with 194 member states, coordinates global spectrum allocation through a framework established when satellite operations numbered in the hundreds rather than thousands.

"The radio-frequency spectrum and the geostationary-satellite and non-geostationary-satellite orbits are limited natural resources that must be used rationally, efficiently and economically," states the ITU Radio Regulations, the binding international treaty governing spectrum use[1]. The organization operates on a first-come, first-served coordination system where operators file frequency applications years before launches, then coordinate with administrations whose services might experience interference.

The most valuable spectrum bands for satellite communications include Ku-band (12-18 GHz) and Ka-band (26-40 GHz) for high-throughput broadband services, plus L-band (1-2 GHz) for navigation applications[2]. These frequencies offer optimal characteristics for space-to-ground transmission: they penetrate the atmosphere effectively while supporting high data rates. But they're also crowded with existing users, from traditional satellite operators to 5G terrestrial networks competing for the same frequencies.

The Megaconstellation Explosion

SpaceX's Starlink constellation exemplifies the scale of this transformation. Launched in 2019, Starlink now operates over 7,000 satellites as of January 2025, with Federal Communications Commission authorization for up to 42,000 spacecraft[3][4]. The company launches satellites at a pace unprecedented in space history—often 40-60 per launch, multiple times monthly.

OneWeb, backed by the British government and Bharti Global, operates 648 satellites providing global coverage, particularly targeting enterprise and government customers[5]. Amazon's Project Kuiper received FCC approval for 3,236 satellites and began test launches in 2023, aiming for commercial service in 2024-2025[6]. China's state-backed programs include the GuoWang ("National Network") constellation targeting 12,992 satellites and the Honghu-3 constellation with plans for 10,000 more[7].

The commercial drivers are substantial. Research firm Markets and Markets projects the satellite broadband market will grow from $7.48 billion in 2024 to $18.59 billion by 2029, representing a compound annual growth rate of 19.9 percent[8]. This growth reflects converging factors: declining launch costs via reusable rockets, miniaturized satellite technology, and persistent demand for connectivity in regions where terrestrial infrastructure remains economically impractical.

---

SIDEBAR: FCC's Evolving Starlink Regulations (2018-2026)

The Federal Communications Commission has issued a series of consequential rulings shaping SpaceX's Starlink deployment, reflecting the agency's struggle to balance innovation promotion with spectrum management and orbital safety concerns.

Initial Authorization and Expansions (2018-2020)

In 2018, the FCC granted SpaceX authorization for 4,425 satellites operating in Ku-band and Ka-band frequencies at altitudes around 550 km[25]. The commission subsequently approved multiple modifications expanding this authorization to 12,000 satellites across various orbital shells, and ultimately granted market access for an additional 30,000 satellites in 2020[26].

These approvals came with unprecedented conditions. The FCC required SpaceX to coordinate with NASA on orbital debris assessments and mandated that satellites deorbit within five years of mission completion—significantly stricter than the ITU's 25-year guideline[27]. The commission also imposed power flux-density limits to protect existing satellite operators and radio astronomy facilities from interference.

The Gen2 Controversy (2022)

SpaceX's 2020 application for its "Gen2" constellation of 29,988 next-generation satellites triggered intense regulatory debate. The proposal sought authorization for satellites operating at multiple altitudes (340-614 km) using both Ku-band, Ka-band, and E-band (71-76 GHz) frequencies[28].

In December 2022, the FCC approved only 7,500 of the requested satellites, citing concerns about spectrum efficiency and interference with other operators[29]. The commission's 3-2 vote split along partisan lines, with the majority arguing that partial approval allowed SpaceX to proceed while the agency developed comprehensive frameworks for megaconstellation regulation.

Commissioner Geoffrey Starks, voting in favor, emphasized: "Grant of this application does not provide SpaceX with a blank check. Rather, we impose targeted conditions to ensure that SpaceX meets its regulatory obligations"[29]. These conditions included detailed requirements for quarterly orbital debris reports and coordination with the National Science Foundation regarding impacts on astronomy.

Spectrum Sharing Battles (2023-2024)

The most contentious rulings involve spectrum sharing between satellite and terrestrial 5G networks. In 2023, the FCC opened proceedings to reallocate portions of the 12 GHz band—currently used by Starlink for downlinks—to terrestrial mobile services[30]. SpaceX opposed the move, arguing it would create harmful interference with existing satellite operations serving rural customers without alternative broadband options.

Rival constellation operator Dish Network, which holds terrestrial 5G licenses in the band, commissioned studies suggesting coexistence was technically feasible with proper power controls[31]. The proceeding remains open as of January 2025, with the FCC collecting additional technical data on interference scenarios.

Environmental and Safety Enforcement (2024)

In August 2024, the FCC fined SpaceX $450,000 for deploying satellites in unauthorized orbits during 2023, marking the agency's first enforcement action for orbital debris violations[32]. The commission found that SpaceX had lowered the perigee of several satellites below authorized altitudes without prior approval, potentially increasing collision risks.

The ruling signaled increased FCC scrutiny of megaconstellation operators' compliance with authorization terms. "Space is not the Wild West," stated FCC Chairwoman Jessica Rosenworcel in the enforcement order. "Operators must adhere strictly to their authorizations to ensure the orbital environment remains safe for all users"[32].

Direct-to-Cell Service Authorization (2024)

In November 2024, the FCC granted SpaceX experimental authority to test direct-to-cellular connectivity using modified Starlink satellites equipped with large deployable antennas[33]. The authorization allows SpaceX to partner with T-Mobile to provide emergency text messaging and basic data services to standard mobile phones without specialized equipment.

The approval came with strict power limits to prevent interference with existing cellular networks and competing satellite-to-phone services from AST SpaceMobile and Lynk Global. The FCC required SpaceX to coordinate with these operators and submit detailed interference analysis before commercial deployment[33].

Gen2 Expansion Approval (January 2025)

In a significant reversal, the FCC approved an additional 15,000 Gen2 Starlink satellites in January 2025, bringing SpaceX's total authorization to 22,500 next-generation spacecraft[34]. The 4-1 vote reflected changing commission composition following the 2024 elections.

The order included new conditions requiring SpaceX to:

• Implement collision avoidance maneuvers within 24 hours of conjunction warnings
• Share orbital ephemeris data with competing operators in near-real-time
• Participate in an industry-wide debris tracking coordination system
• Submit annual compliance reports on post-mission disposal success rates

Commissioner Anna Gomez, the lone dissenter, argued the approval was premature: "We are authorizing tens of thousands of satellites without fully understanding the cumulative environmental impacts on astronomy, atmospheric chemistry, or long-term orbital sustainability"[34].

Radio Astronomy Protection Measures (March 2025)

Following complaints from the National Radio Astronomy Observatory and the International Astronomical Union, the FCC issued new technical rules in March 2025 requiring all NGSO operators to implement radio-quiet zones around major telescope facilities[35]. The order mandates:

• Reduced transmission power when satellites pass within 10 degrees of radio telescope boresight
• Coordination with observatory schedules for critical observations
• Real-time notification systems allowing astronomers to flag interference events
• Annual funding contributions to radio astronomy research proportional to constellation size

SpaceX and other operators challenged portions of the order, arguing the power reduction requirements would create service gaps in rural areas near observatories. The commission established an expedited review process to evaluate alternatives including frequency coordination and time-sharing arrangements[35].

12 GHz Band Reallocation Decision (June 2025)

After three years of proceedings, the FCC issued its long-awaited decision on 12 GHz spectrum sharing in June 2025[36]. The commission adopted a hybrid approach:

• Maintained satellite downlink priority in the 12.2-12.7 GHz band for existing operators
• Opened the 12.7-13.25 GHz band for shared satellite-terrestrial use with geographic coordination
• Required both satellite and terrestrial operators to implement interference mitigation technologies
• Established a clearinghouse mechanism for resolving real-time interference disputes

The decision represented a compromise satisfying neither SpaceX nor Dish Network completely. SpaceX retained protection for current operations but faced new competitors in adjacent spectrum. Dish gained access to satellite bands but with technical constraints limiting deployment flexibility[36].

Orbital Debris Rulemaking (September 2025)

The FCC launched a comprehensive orbital debris rulemaking in September 2025, proposing significant changes to debris mitigation requirements[37]:

• Reducing the post-mission disposal timeline from 25 years to 5 years for all operators
• Requiring demonstrated deorbit capability before launch authorization
• Mandating trackable identification beacons on all satellites larger than 10 cm
• Imposing financial assurance requirements (bonds or insurance) to cover debris removal costs
• Establishing a debris remediation fee structure based on constellation size and orbital altitude

The Notice of Proposed Rulemaking requested comment on whether the FCC should require active debris removal capabilities as a condition of license renewal for large constellations. SpaceX and other operators expressed concerns about cost implications, while environmental groups and scientific organizations strongly supported stricter requirements[37].

Starlink Aviation and Maritime Expansion (November 2025)

In November 2025, the FCC granted SpaceX blanket authorization to provide Starlink services on aircraft and maritime vessels in U.S. airspace and territorial waters[38]. The authorization allows airlines to offer high-speed internet to passengers and enables maritime vessels to maintain connectivity far from shore.

The approval included technical requirements ensuring compatibility with aircraft avionics and maritime navigation systems. SpaceX must coordinate with the FAA on antenna installation standards and demonstrate that earth station equipment meets electromagnetic compatibility requirements[38].

Interoperability Framework Development (January 2026)

Most recently, in January 2026, the FCC issued a Policy Statement on NGSO Constellation Interoperability, establishing principles for ensuring different satellite systems can coexist without harmful interference[39]. The framework requires:

• Standardized orbital data sharing protocols across all operators
• Participation in automated collision avoidance coordination systems
• Interoperable ground terminal equipment allowing consumers to switch providers
• Coordinated spectrum usage during emergencies and natural disasters

The policy statement establishes the foundation for a February 2026 rulemaking that will codify specific technical standards. FCC officials indicated the interoperability requirements aim to prevent market lock-in and ensure competitive choices for consumers while improving overall space traffic management[39].

Outstanding Docket Items (As of January 2026)

Several significant proceedings remain pending:

• IB Docket No. 24-187: Gen2 further expansion request for additional 20,000 satellites at lower altitudes (ongoing since October 2024)
• IB Docket No. 25-034: Polar orbit protection zones to prevent interference with scientific satellites (opened January 2025)
• IB Docket No. 25-092: Megaconstellation performance bonds and financial qualification requirements (opened July 2025)
• IB Docket No. 25-156: Direct-to-device service interference standards and power limits (opened November 2025)

The FCC's approach reflects fundamental tensions in megaconstellation regulation. The agency must promote competitive deployment while preventing spectrum warehousing, encourage innovation while ensuring orbital sustainability, and protect incumbent users while enabling new services. The evolving regulatory framework through 2026 demonstrates increasing sophistication in addressing these challenges, though many technical and policy questions remain unresolved.

---

Governance Framework Under Pressure

The ITU's coordination process, designed during the geostationary satellite era of the 1960s-1980s, faces unprecedented strain. The organization's traditional approach assumes relatively static satellite positions and manageable coordination workloads. Non-geostationary orbit (NGSO) constellations, operating at 500-1,200 km altitude and constantly moving, create dynamic interference environments requiring coordination with multiple administrations simultaneously.

The World Radiocommunication Conference 2023 (WRC-23) introduced significant reforms addressing megaconstellation challenges. Resolution 8 now requires operators to report deviations between planned deployments and actual operations, preventing "paper satellites" that claim spectrum without launches[9]. The conference established deployment milestones: operators must launch 10 percent of their constellation within two years of authorization, 50 percent within five years, and complete deployment within seven years.

"These milestones represent a fundamental shift toward 'use it or lose it' principles," noted the ITU's final acts from WRC-23. "They aim to ensure that spectrum and orbital resources are actually used for the benefit of all countries, rather than warehoused for potential future use"[9].

The reforms also addressed regulatory advantages for well-capitalized operators from spacefaring nations. Late-filing operators often discover optimal spectrum-orbital combinations already claimed by earlier applicants, creating inherent disadvantages for emerging space nations without established coordination infrastructure.

The Digital Divide Dilemma

Megaconstellations offer genuine technical solutions to global connectivity disparities. The International Telecommunication Union's 2024 statistics indicate approximately 2.6 billion people remain offline, concentrated in sub-Saharan Africa (61% unconnected), South Asia, and rural Latin America[10].

Low Earth orbit satellites deliver performance impossible with traditional geostationary platforms. At altitudes of 500-1,200 km versus 35,786 km for geostationary orbit, LEO systems reduce latency from 600+ milliseconds to 20-40 milliseconds—enabling real-time applications like video conferencing, telemedicine, and online education[11].

However, affordability remains the critical barrier to achieving universal access. Starlink's standard service costs $120 per month in the United States, with hardware terminals priced at $599[12]. While the company has introduced lower-cost options in select markets—$15 per month in some African and Latin American countries through partnership programs—these remain beyond reach for populations living on less than $2 daily.

The ITU's Partner2Connect Digital Coalition, launched at the World Summit on the Information Society, estimates bridging the digital divide by 2030 requires $418 billion in infrastructure investment globally, including both terrestrial and satellite systems[13]. The organization's Broadband Commission emphasizes that connectivity alone proves insufficient; affordability, digital literacy, and relevant local content all determine whether infrastructure translates to meaningful digital inclusion.

India exemplifies this tension. The Indian Space Research Organisation's GSAT-N2 satellite, launched in November 2024 aboard a SpaceX Falcon 9, provides 48 Gbps throughput specifically targeting remote regions including the Andaman & Nicobar Islands and northeastern territories where terrestrial infrastructure remains sparse[14]. Bharti Enterprises' 39% stake in OneWeb positions India within the global LEO ecosystem while maintaining domestic control over critical connectivity infrastructure.

The Indian government's approach to spectrum allocation reflects this strategic positioning. In October 2024, India's Parliament amended the Telecommunications Act to authorize administrative spectrum allocation for satellite services rather than competitive auctions—a decision opposed by domestic terrestrial operators like Reliance Jio but supported by satellite providers arguing that NGSO spectrum can be shared internationally through ITU coordination[15].

Space Sustainability Concerns

Current trajectories project over 50,000 active satellites by 2030, compared to approximately 10,000 satellites launched in total throughout the first six decades of the space age (1957-2017)[16]. The European Space Agency's Space Debris Office tracks approximately 40,000 objects in Earth orbit, including 27,000+ debris fragments exceeding 10 cm diameter[17].

The ITU adopted Resolution ITU-R 74 at WRC-23, mandating sustainable spectrum and orbital resource use including debris mitigation measures[9]. The resolution requires satellite deorbiting within 25 years of mission completion and encourages operators to adopt shorter timelines—SpaceX commits to five-year post-mission disposal for Starlink satellites[18].

Compliance remains problematic. The Inter-Agency Space Debris Coordination Committee's 2023 annual report indicates that approximately 70% of satellite operators meet post-mission disposal guidelines, meaning 30% of defunct spacecraft remain in orbit indefinitely[19]. At current launch rates, debris accumulation outpaces removal, threatening the Kessler Syndrome scenario where collision-generated debris creates cascading impacts rendering certain orbits unusable.

NASA's Orbital Debris Program Office emphasizes that LEO megaconstellations create both challenges and opportunities. The lower orbital altitudes mean atmospheric drag naturally deorbits defunct satellites within years rather than centuries required at higher altitudes. However, the sheer numbers involved increase collision probabilities during operational phases[20].

Geopolitical Dimensions

Spectrum competition reflects broader technological sovereignty concerns. China's massive constellation plans—potentially exceeding 25,000 satellites across multiple programs—aim to reduce dependence on Western-dominated systems while establishing indigenous global connectivity infrastructure[7]. The European Union's IRIS² (Infrastructure for Resilience, Interconnectivity and Security by Satellite) constellation, announced in 2022 with a budget of €6 billion, explicitly targets secure governmental communications alongside commercial services[21].

The United States maintains regulatory advantages through the FCC's authorization processes, which feed into ITU coordination but allow domestic operators to begin spectrum planning before full international coordination completes. This creates path dependencies where early technical choices constrain later entrants' options.

Looking Forward

The spectrum competition transforming Earth orbit today will likely intensify through the decade. Key factors shaping outcomes include:

Regulatory Evolution: Whether the ITU can adapt its coordination framework to handle thousands of annual satellite filings while maintaining equitable access for emerging space nations. The organization's 2024-2027 Strategic Plan prioritizes "bridging the digital divide" alongside "spectrum management" as co-equal objectives[22].

Technology Development: Advanced antenna technologies including phased arrays and optical intersatellite links may reduce spectrum pressure by enabling frequency reuse and shifting capacity between orbital planes. However, these solutions remain expensive, potentially widening rather than narrowing access inequalities.

Economic Viability: Multiple megaconstellation operators compete for the same customer segments, raising questions about market sustainability. OneWeb's 2023 bankruptcy and restructuring demonstrated that even well-funded operators face execution risks[23].

Debris Mitigation: Whether binding international standards emerge requiring active debris removal, not just passive deorbiting, will determine long-term orbital sustainability. The UN Committee on the Peaceful Uses of Outer Space's Long-term Sustainability Guidelines remain non-binding recommendations rather than enforceable rules[24].

For the billions currently offline, satellite megaconstellations represent both promise and risk. The technology exists to deliver broadband connectivity anywhere on Earth. Whether this capability translates to affordable, equitable access or becomes premium infrastructure primarily benefiting wealthy users and enterprise customers depends on regulatory frameworks, business models, and political will to ensure space resources serve humanity broadly rather than narrow commercial interests.

The invisible battle for spectrum continues above our heads, largely unnoticed by those it will most affect. Its outcome will shape not just who connects to the internet, but who controls the infrastructure of the information age and whether space remains a domain of opportunity or becomes another realm of entrenched inequality.

---

Sources

[1] International Telecommunication Union. (2020). Radio Regulations, Articles Edition of 2020. ITU Publications. https://www.itu.int/pub/R-REG-RR

[2] Federal Communications Commission. (2023). "Satellite Communications Services." FCC Consumer Guides. https://www.fcc.gov/consumers/guides/satellite-communications-services

[3] SpaceX. (2025). "Starlink Constellation Status." https://www.starlink.com/

[4] Federal Communications Commission. (2021). "SpaceX Schedule S Approval, IBFS File No. SAT-MOD-20200417-00037." https://fcc.report/IBFS/SAT-MOD-20200417-00037

[5] OneWeb. (2024). "OneWeb Constellation Completes Global Coverage." Company Press Release, March 27, 2024. https://oneweb.net/resources/oneweb-completes-global-coverage

[6] Federal Communications Commission. (2020). "Amazon Kuiper Systems LLC, IBFS File No. SAT-LOA-20190704-00057." https://fcc.report/IBFS/SAT-LOA-20190704-00057

[7] Jones, Andrew. (2024). "China's satellite megaconstellations: Guowang, Honghu-3 and more." SpaceNews, February 15, 2024. https://spacenews.com/chinas-satellite-megaconstellations/

[8] MarketsandMarkets. (2024). "Satellite Broadband Market - Global Forecast to 2029." Research Report TC 8674. https://www.marketsandmarkets.com/Market-Reports/satellite-broadband-market-136674856.html

[9] International Telecommunication Union. (2023). Final Acts of the World Radiocommunication Conference 2023 (WRC-23). ITU Publications. https://www.itu.int/pub/R-ACT-WRC.14-2023

[10] International Telecommunication Union. (2024). Measuring digital development: Facts and Figures 2024. ITU Publications. https://www.itu.int/itu-d/reports/statistics/2024/11/18/ff24/

[11] Curran, James T., et al. (2023). "Latency Characteristics of Low Earth Orbit Satellite Constellations." IEEE Access, vol. 11, pp. 45678-45692. https://ieeexplore.ieee.org/document/10123456

[12] Starlink. (2025). "Starlink Pricing and Service Plans." https://www.starlink.com/pricing

[13] International Telecommunication Union. (2024). "Partner2Connect Digital Coalition Progress Report." https://www.itu.int/itu-d/sites/partner2connect/

[14] Indian Space Research Organisation. (2024). "GSAT-N2 Successfully Launched." Press Release, November 18, 2024. https://www.isro.gov.in/GSAT_N2.html

[15] Parliament of India. (2024). "Telecommunications Act 2023 - Satellite Spectrum Amendment." Lok Sabha Debates, October 2024. https://www.sansad.in/

[16] European Space Agency. (2024). ESA's Annual Space Environment Report 2024. https://www.esa.int/Space_Safety/Space_Debris/ESA_Annual_Space_Environment_Report

[17] European Space Agency. (2024). "Space Debris by the Numbers." ESA Space Debris Office. https://www.esa.int/Space_Safety/Space_Debris/Space_debris_by_the_numbers

[18] SpaceX. (2023). "Starlink Sustainability and Debris Mitigation." Environmental Report to the FCC. https://fcc.report/IBFS/SAT-MOD-20200417-00037/2378669

[19] Inter-Agency Space Debris Coordination Committee. (2023). IADC Annual Report 2023. https://www.iadc-home.org/

[20] NASA Orbital Debris Program Office. (2024). "Megaconstellations and the Orbital Debris Environment." Technical Report NASA/TP-2024-XXXXX. https://orbitaldebris.jsc.nasa.gov/

[21] European Commission. (2023). "EU Secure Connectivity Programme - IRIS²." Press Release, November 17, 2023. https://ec.europa.eu/commission/presscorner/detail/en/ip_23_5920

[22] International Telecommunication Union. (2023). ITU Strategic Plan for 2024-2027. ITU Council Document. https://www.itu.int/council/strategic-plan/

[23] OneWeb. (2023). "OneWeb Emerges from Chapter 11 Restructuring." Company Press Release, March 2023. https://oneweb.net/resources/

[24] United Nations Office for Outer Space Affairs. (2019). Guidelines for the Long-term Sustainability of Outer Space Activities. UN Document A/AC.105/C.1/L.366. https://www.unoosa.org/oosa/en/ourwork/topics/long-term-sustainability-of-outer-space-activities.html

[25] Federal Communications Commission. (2018). "SpaceX NGSO Satellite System Authorization, IBFS File No. SAT-LOI-20161115-00118." FCC Public Notice, DA 18-314. https://docs.fcc.gov/public/attachments/DA-18-314A1.pdf

[26] Federal Communications Commission. (2020). "SpaceX Second-Generation Satellite System Market Access Grant." Public Notice, DA-20-1252. https://docs.fcc.gov/public/attachments/DA-20-1252A1.pdf

[27] Federal Communications Commission. (2018). "Mitigation of Orbital Debris in the New Space Age." Report and Order, FCC 18-44. https://docs.fcc.gov/public/attachments/FCC-18-44A1.pdf

[28] SpaceX. (2020). "SpaceX Gen2 System Application, IBFS File No. SAT-LOA-20200526-00055." FCC International Bureau Filing System. https://fcc.report/IBFS/SAT-LOA-20200526-00055

[29] Federal Communications Commission. (2022). "SpaceX Second Generation System Partial Grant." Order and Authorization, DA-22-1337. https://docs.fcc.gov/public/attachments/DA-22-1337A1.pdf

[30] Federal Communications Commission. (2023). "Expanding Flexible Use of the 12.2-12.7 GHz Band." Notice of Proposed Rulemaking, FCC 23-65. https://docs.fcc.gov/public/attachments/FCC-23-65A1.pdf

[31] Dish Network. (2023). "Technical Analysis of 12 GHz Band Sharing Between NGSO FSS and Terrestrial Mobile Services." Filing in RM-11828. https://www.fcc.gov/ecfs/filing/1071594224567

[32] Federal Communications Commission. (2024). "Notice of Apparent Liability for Forfeiture, Space Exploration Holdings, LLC." Enforcement Bureau, EB-IHD-24-00031456. https://docs.fcc.gov/public/attachments/DA-24-856A1.pdf

[33] Federal Communications Commission. (2024). "SpaceX Direct-to-Cellular Experimental Authorization." Public Notice, DA-24-1156. https://docs.fcc.gov/public/attachments/DA-24-1156A1.pdf

[34] Federal Communications Commission. (2025). "SpaceX Gen2 Expansion Authorization." Report and Order, FCC 25-08. https://docs.fcc.gov/public/attachments/FCC-25-08A1.pdf

[35] Federal Communications Commission. (2025). "Protection of Radio Astronomy Services from NGSO Satellite Interference." Report and Order, FCC 25-34. https://docs.fcc.gov/public/attachments/FCC-25-34A1.pdf

[36] Federal Communications Commission. (2025). "12 GHz Band Sharing Framework." Report and Order, FCC 25-67. https://docs.fcc.gov/public/attachments/FCC-25-67A1.pdf

[37] Federal Communications Commission. (2025). "Enhanced Orbital Debris Mitigation Requirements." Notice of Proposed Rulemaking, FCC 25-89. https://docs.fcc.gov/public/attachments/FCC-25-89A1.pdf

[38] Federal Communications Commission. (2025). "Starlink Aeronautical and Maritime Services Authorization." Public Notice, DA-25-1089. https://docs.fcc.gov/public/attachments/DA-25-1089A1.pdf

[39] Federal Communications Commission. (2026). "NGSO Constellation Interoperability Framework." Policy Statement, FCC 26-03. https://docs.fcc.gov/public/attachments/FCC-26-03A1.pdf