Summary of Comments (Comment period closed yesterday)
I. Introduction
On June 20, 2025, the FCC Space Bureau issued a Public Notice seeking public comment on a portion of a modification application filed by AST & Science, LLC (AST). In its original application, AST sought to modify its non-geostationary orbit (NGSO) license to authorize a 248-satellite constellation to provide Supplemental Coverage from Space (SCS), based on spectrum lease arrangements with AT&T and Verizon in the 700 MHz and 800 MHz bands. The application also requested a waiver of the Geographically Independent Area (GIA) entry requirement1. (NOTE: There may have been filings on ICFS that we have not included in this summary of ECFS Comments)
The Space Bureau’s Public Notice in SB Docket No. 25-201 accepted for filing only the telemetry, tracking, and telecommand (TT&C) portions of AST’s request. The Commission sought comment on AST’s proposed TT&C operations in the 430-440 MHz, 2025-2110 MHz, 2200-2290 MHz, and 45.5-47 GHz bands. The Bureau deferred consideration of the proposed SCS and mobile-satellite service (MSS) operations, stating it “does not at this time accept for filing AST’s request for operations other than TT&C.” The comment deadline was set for July 21, 2025, with reply comments due August 5, 20252.
II. Issues and Arguments
A. Procedural Issues Regarding Application Completeness and Public Disclosure
Opposition to Accepting the SCS Application: T-Mobile urged the Space Bureau to hold the SCS portion of AST’s application in abeyance until AST makes its confidential “Annex B – SCS 700/800 MHz Interference Analysis” and associated coverage maps publicly available. T-Mobile argued that the FCC’s SCS framework requires public disclosure to allow for a meaningful assessment of interference risk and that the burden is on AST to demonstrate non-interference, particularly given its GIA waiver request. It contrasted AST’s approach with the more extensive public technical data required of T-Mobile’s own SCS partner, SpaceX. It noted that AST’s partners, AT&T and Verizon, had previously argued for robust technical showings from applicants3. In a later filing, T-Mobile dismissed AST’s comparison to the SpaceX application as a "false equivalency," noting that the contiguous spectrum rights held by T-Mobile presented a less complex interference scenario than AST’s proposal. T-Mobile also cited uncorrected errors in AST’s leasing notifications as a reason the application should not be deemed complete4.
Support for Placing Application on Public Notice: AST urged the Commission to dismiss T-Mobile’s request, arguing that redactions were minimal, the full text of its interference analysis was public, and sufficient unredacted information was provided for licensees to assess interference risks. AST contended there was no basis to deviate from the process used for SpaceX, which submitted additional technical information only after the Space Bureau requested it post-public notice5.
Other Stakeholders: USA Performance Products, Inc. and Open Communications Organization, Inc. (OCO) echoed T-Mobile’s concerns, arguing that AST’s application lacked transparency due to redacted maps and failed to meet the burden of proving non-interference. They also argued that if the operations are considered "experimental," all technical data should be publicly released6.
B. Technical Issues Regarding the Proposed Constellation
Orbital Safety and Light Pollution: The National Aeronautics and Space Administration (NASA) filed comments raising concerns about the constellation’s colocation within a “debris-rich orbital regime” and the associated collision risk. NASA stated it has a Space Act Agreement (SAA) with AST for ongoing coordination to mitigate these risks. Additionally, NASA’s preliminary assessment found the constellation’s projected light pollution “exceeds thresholds recommended by the astronomical community” as outlined in International Astronomical Union (IAU) guidance. The agency confirmed its continued evaluation of the constellation's trackability and disposal plans7.
TT&C Operations in the 2025-2110 MHz Band: While expressing no opinion on the application's merits, The Society of Broadcast Engineers, Inc. (SBE) requested that any authorization include a condition requiring frequency coordination with SBE. SBE argued this is necessary to protect incumbent Broadcast Auxiliary Service (BAS), Cable Television Relay Service (CARS), and Local Television Transmission Service (LTTS) operations from harmful interference, consistent with FCC rules8.
TT&C Operations in the 902-928 MHz Band: One amateur operator objected to AST's proposed use of this band, citing potential interference to existing amateur, commercial (Part 15), and personal communications devices9.
C. Widespread Opposition to TT&C Operations in the 430-440 MHz Band
A global coalition of individual amateur radio operators, national amateur radio societies, and specialized organizations filed in opposition to AST’s request to use the 430-440 MHz band for TT&C. The arguments centered on technical interference, regulatory violations, and harm to public interest.
Argument: Harmful Interference to Incumbent Services: The overwhelming majority of filers argued that the 248-satellite constellation would cause unacceptable harmful interference to a wide range of established services in the 430-440 MHz band.
Amateur Radio Service: Filers argued the operations would disrupt weak-signal communications, amateur satellite links, terrestrial repeater networks, digital voice modes, educational activities, and entry-level operations. They emphasized the cumulative interference effect of a large constellation and the global nature of the impact10.
Emergency Communications: A large number of filers, including ARES members and radio groups, stressed that the 70cm band is a critical resource for public safety and emergency communications provided by volunteers, which would be jeopardized by commercial encroachment11.
Government Radiolocation Service: Several U.S. filers identified the primary user of the band as the U.S. government for military radiolocation, specifically ballistic missile early warning radar systems. They argued that hundreds of satellites would create a significant problem for national defense12.
Amateur Radio on the International Space Station (ARISS): ARISS-USA filed a petition to deny, arguing the operations would seriously impact its mission, which includes providing backup communications for astronauts and its global STEAM educational program13.
Argument: Violation of International and Domestic Regulations: Filers contended that the authorization would contravene established regulatory frameworks.
Misuse of ITU Regulations: Numerous international amateur radio societies and individuals argued the request represents a misuse or "regulatory arbitrage" of Article 4.4 of the International Telecommunication Union (ITU) Radio Regulations (RR). They contended the FCC would be improperly authorizing operations that, while not permitted in the U.S., would cause harmful interference in other countries where the amateur service holds primary status. Several filers also argued the plan violates ITU RR Article 4.214.
Circumvention of IARU Coordination: Multiple groups, including the Union of Swiss Shortwave Amateurs (USKA), argued that AST is circumventing the globally recognized coordination process managed by the International Amateur Radio Union (IARU) for the 435-438 MHz satellite sub-band. They argued a grant would undermine the IARU’s ITU-mandated role and create a "regulatory vacuum"15.
Inappropriate Band for Commercial Use: A consistent theme was that the 430-440 MHz band is not allocated for commercial MSS TT&C and that AST should be directed to use its other authorized TT&C bands (e.g., S-band) or other internationally recognized commercial allocations16.
Argument: Prior Non-Compliance and Insufficient Technical Showing:
Allegations of Ongoing Interference: Numerous filers from Europe and the U.S. alleged that AST’s existing satellites (BlueWalker-3 and Bluebirds) are already causing interference or are operating non-compliantly. These claims were supported by signal observation data and references to alleged regulatory action taken by Germany’s national regulator, BNetzA. The Radio Amateur Satellite Corporation (AMSAT) cited a specific observation of interference to the InspireSAT-1 satellite17.
Insufficient Analysis: Filers argued AST’s interference analysis was deficient for failing to study the impact on the Amateur Radio Service18.
Requested Actions by Opponents: The vast majority of filers requested the Commission deny AST’s request to use the 430-440 MHz band. Many European amateur radio societies also requested a firm, explicit confirmation from the FCC that AST’s satellites will not cause harmful interference to authorized services in their respective countries19. A few filers also urged the Commission to revoke AST’s existing experimental licenses for alleged non-compliance20.
III. Conclusion
The Space Bureau’s limited public notice on AST’s modification application has revealed two distinct areas of significant contention. First, a procedural dispute led by T-Mobile raises questions about the completeness of the deferred SCS portion of the application, specifically regarding the need for public disclosure of technical interference data before the application is accepted for filing. AST maintains it has provided sufficient information and should follow established precedent.
Second, the accepted TT&C portion of the application has drawn widespread and unified international opposition, with almost exclusive focus on the proposed use of the 430-440 MHz band. The opposition, comprising a global coalition of the amateur radio community and its representative bodies, argues that the authorization would cause unacceptable harmful interference to critical non-commercial services, including emergency communications, scientific and educational activities, and international satellite operations. Opponents further argue that the proposal is a non-conforming use of spectrum that violates international regulations and circumvents established coordination frameworks. These regulatory and technical objections are amplified by claims that AST’s existing satellites are already causing interference and by the argument that the company has other, more appropriate commercial spectrum available for its TT&C functions. In contrast to the heavy opposition in the 430-440 MHz band, filings on the other TT&C bands were limited to requests for standard technical coordination. The record reflects a fundamental conflict between AST’s commercial operational plans and the established, globally coordinated uses of the 430-440 MHz band by amateur and government services.
[Application, AST & Science, LLC, https://www.fcc.gov/ecfs/document/106201991509823/1]
[Public notice, Space Bureau, https://docs.fcc.gov/public/attachments/DA-25-532A1.pdf]
[Letter, T-Mobile USA, Inc., https://www.fcc.gov/ecfs/document/106262778126093/1]
[Letter, T-Mobile USA, Inc., https://www.fcc.gov/ecfs/document/10716096859141/1]
[Exhibit, AST & Science, LLC, https://www.fcc.gov/ecfs/document/10707665020859/1]
[Letter, USA Performance Products, Inc, https://www.fcc.gov/ecfs/document/10721241006832/1; Letter, Open Communications Organization, Inc., https://www.fcc.gov/ecfs/document/107213094624396/1]
[Comment, National Aeronautics and Space Administration, https://www.fcc.gov/ecfs/document/10721554228856/1; Comment, National Aeronautics and Space Administration, https://www.fcc.gov/ecfs/document/1072164485884/1]
[Comment, The Society of Broadcast Engineers, Inc., https://www.fcc.gov/ecfs/document/1072165885325/1]
[Comment, Douglas Datwyler, https://www.fcc.gov/ecfs/document/10721086848083/1]
[Opposition, Rui Jorge dos Santos Cruz, https://www.fcc.gov/ecfs/document/1071236668196/1; Comment, Brian B Whitaker, https://www.fcc.gov/ecfs/document/10716806609355/1; Comment, Joel Wilhite, https://www.fcc.gov/ecfs/document/10721769314855/1; Comment, Neil R. Ormos, https://www.fcc.gov/ecfs/document/10722083423526/1]
[Comment, Charles Fellenbaum, https://www.fcc.gov/ecfs/document/1071747917400/1; Comment, Pend Oreille County Radio Group, Patrick Molvik, P.E., https://www.fcc.gov/ecfs/document/107211354611028/1; Comment, Matthew Basanta, https://www.fcc.gov/ecfs/document/1072202839794/1]
[Comment, James M Richardson, Jr., https://www.fcc.gov/ecfs/document/10721118949344/1; Comment, Marilyn A Richardson, https://www.fcc.gov/ecfs/document/10721248626061/1; Comment, Steven K. Stroh, https://www.fcc.gov/ecfs/document/1072167578252/1]
[Comment, ARISS-USA, Frank H. Bauer, https://www.fcc.gov/ecfs/document/1072175432072/1]
[Petition, Mario Lorenz, https://www.fcc.gov/ecfs/document/10714174724585/1; Petition, Peter Gülzow (DB2OS), https://www.fcc.gov/ecfs/document/10718802726591/1; Complaint, Union de Radioaficionados Espaoles, https://www.fcc.gov/ecfs/document/10721144904101/1; Opposition, ARRL, The National Association for Amateur Radio, https://www.fcc.gov/ecfs/document/1072110100328/1]
[Comment, Tobias Schlegel, Tobias Schlegel, https://www.fcc.gov/ecfs/document/107181484515951/1; Comment, Union of Swiss Shortwave Amateurs, https://www.fcc.gov/ecfs/document/10721283212324/1]
[Comment, Ross Greves, https://www.fcc.gov/ecfs/document/1072090190527/1; Comment, Open Research Institute, Inc., https://www.fcc.gov/ecfs/document/1072189554716/1; Opposition, ARRL, The National Association for Amateur Radio, https://www.fcc.gov/ecfs/document/1072110100328/1]
[Petition, Mario Lorenz, https://www.fcc.gov/ecfs/document/10714174724585/1; Comment, Radio Amateur Satellite Corporation (AMSAT), https://www.fcc.gov/ecfs/document/10721071371102/1; Complaint, Union de Radioaficionados Espaoles, https://www.fcc.gov/ecfs/document/10721144904101/1; Comment, Ronald Nelson, https://www.fcc.gov/ecfs/document/10722299593495/1]
[Comment, Wayne C. Greaves, https://www.fcc.gov/ecfs/document/107171643015374/1; Comment, RSGB, https://www.fcc.gov/ecfs/document/10721151315294/1]
[Comment, Cyprus Amateur Radio Society, https://www.fcc.gov/ecfs/document/10718367424325/1; Comment, Robbie Phelan Ei2iP, https://www.fcc.gov/ecfs/document/1071890980730/1; Letter, POLSKI ZWIĄZEK KRÓTKOFALOWCÓW, https://www.fcc.gov/ecfs/document/10721234437286/1]
[Comment, R.W. Schmitz, https://www.fcc.gov/ecfs/document/10719232561310/1; Comment, Steven K. Stroh, https://www.fcc.gov/ecfs/document/1072167578252/1]