Daily Ex Parte, Aug 15, 2025
SpaceX (AST's Orbital Debris Assessment Report), NextNav (NPRM petition), Grain & T- Mobile (800MHz & 600 MHz), GPS Innovation Alliance (PNT, NextNav, Xona)
Filers
GPS Innovation Alliance — PNT, NextNav, Xona
Grain Management & T-Mobile — Deal and update on market progress
NextNav Inc. — Reiterating its call for the FCC to promptly issue an NPRM
Space Exploration Holdings, LLC — Focus on AST’s Orbital Debris Assessment Report
GPS Innovation Alliance
Proceeding(s): 24-240, 25-110
Date of Meeting: August 12, 2025
Date Disseminated: August 15, 2025
Participants:
Lisa L. Dyer, Executive Director, GPS Innovation Alliance (GPSIA)
Russell Fox, Mintz (Counsel for GPSIA member Trimble Inc.)
Met with: Jay Schwarz, Chief of the Space Bureau, FCC
Summary of Discussion:
Representatives from the GPS Innovation Alliance (GPSIA) and Trimble Inc. met with Jay Schwarz of the FCC's Space Bureau to discuss several proceedings related to positioning, navigation, and timing (PNT) technologies. The discussion covered three main topics:
Status of Alternative PNT Proceedings: The parties discussed the current status of the FCC's proceedings considering alternative PNT systems, including the Notice of Inquiry in WT Docket No. 25-110 and the NextNav Petition for Rulemaking in WT Docket No. 24-240.
GPSIA Priorities: GPSIA outlined its key priorities, emphasizing the need for increased government funding for both the GPS satellite constellation and its associated ground stations. They also raised concerns about the growing use of spoofing and jamming against global navigation satellite systems, particularly outside of traditional conflict zones, which is negatively impacting aviation and maritime commerce. GPSIA urged the FCC to continue its robust enforcement of rules designed to prevent such harmful activities.
Xona Space Systems Application: GPSIA informed the FCC that it has been working cooperatively with Xona Space Systems, Inc. (Xona) to resolve the technical issues that GPSIA had previously raised in its Petition to Deny Xona's satellite application (ICFS File No. SAT-LOA-20230711-00165).
Source: [NOTICE OF EXPARTE, GPS Innovation Alliance, https://www.fcc.gov/ecfs/document/10814107640735/1]
Grain Management & T-Mobile
Proceeding(s): 25-178
Date of Meeting: August 12, 2025
Date Disseminated: August 14, 2025
Participants:
Federal Communications Commission (Wireless Bureau):
Stephanie Asous
Cameron Duncan
Stacy Ferraro
Susannah Larson
Roger Noel
Thomas Reed
Grain Management, LLC:
Ari Q. Fitzgerald
Tanner Goode
Michael McKenzie
Ryan Thompson
Zaid Umar
T-Mobile USA, Inc.:
Eric DeSilva
Tom Dombrowsky
Nancy Victory
Summary of Discussion:
Representatives from Grain Management, LLC ("Grain") and T-Mobile USA, Inc. ("T-Mobile") met with staff from the FCC's Wireless Bureau to discuss their pending license assignment applications and associated waiver requests. The discussion centered on a transaction wherein Grain will acquire T-Mobile's nationwide 800 MHz spectrum block, and T-Mobile will acquire Grain's 600 MHz license portfolio.
The core of the presentation was to update the FCC on the progress and advocate for swift approval of the transaction and waivers. Grain outlined its plan to create a market for the 800 MHz spectrum, targeting utilities, rural and regional wireless operators, and other enterprises. The primary use case emphasized is for critical infrastructure, enabling utilities to deploy private networks to enhance grid resiliency, improve efficiency, and strengthen cybersecurity.
Grain argued that the FCC's standard build-out and discontinuance rules are ill-suited for this unique, market-based transition of spectrum. They explained that building a nationwide customer base among utilities is a multi-year process, as many are "late-stage adopters" who require regulatory certainty before making significant investments. Therefore, they have requested waivers to provide a longer, more flexible build-out timeline, which they state is essential for the project's success.
Key points made during the meeting include:
Market Progress: Grain reported significant progress in building a pipeline of potential utility partners. They have signed numerous Letters of Intent (LOIs), are in an RFP process with one of the nation's largest utilities, and have active discussions with utilities that collectively serve over 96% of the U.S. population.
Need for Regulatory Certainty: The primary concern raised by potential utility partners is the build-out timeline. Grain stressed that granting the requested waivers would provide the certainty needed to unlock investment from these critical infrastructure providers.
Overwhelming Public Support: The applicants highlighted that the formal comment period, which closed on July 8, 2025, yielded overwhelmingly positive responses. They cited supportive comments from a wide range of industry stakeholders, including the Competitive Carriers Association (CCA), Dominion Energy, Edison Electric Institute (EEI), Southern California Edison (SCE), the Utility Broadband Alliance (UBBA), and the Utilities Technology Council (UTC). These parties uniformly endorsed the transaction and the necessity of the waivers to put the spectrum to productive use for critical infrastructure.
Addressing Opposition: The presentation acknowledged and dismissed opposition from two parties. They characterized the petition from the Rural Wireless Association (RWA) as a mischaracterization of the application and rejected its proposed conditions as contrary to Commission policy. They also described allegations from EchoStar regarding T-Mobile's use of the 800 MHz spectrum as "baseless and irrelevant."
In conclusion, Grain and T-Mobile asserted that the record is ripe for a decision. They urged the Commission to grant swift approval of the applications and waivers, arguing that the transaction is strongly in the public interest and will facilitate the deployment of valuable spectrum to enhance the nation's critical infrastructure.
Source: [NOTICE OF EXPARTE, Grain Management, LLC, https://www.fcc.gov/ecfs/document/108140045727370/1]
NextNav Inc.
Proceeding(s): 25-110, 24-240
Date of Meeting: August 12, 2025
Date Disseminated: August 15, 2025
Participants: Renee Gregory (Vice President of Regulatory Affairs, NextNav Inc.) met with Krista Senell (Chief of Staff and Senior Counsel to Commissioner Trusty) and William Holloway (Legal Advisor to Commissioner Trusty).
Summary of Discussion:
In a meeting with legal advisors to Commissioner Trusty, Renee Gregory of NextNav Inc. presented the company's proposal to enable 5G-based 3D Positioning, Navigation, and Timing (PNT) services in the Lower 900 MHz band (902-928 MHz). The discussion covered the key aspects of NextNav's Petition for Rulemaking (WT Docket No. 24-240) and its relevance to the FCC's broader inquiry into PNT technologies (WT Docket No. 25-110).
Gregory argued that swift FCC action to optimize the Lower 900 MHz band would achieve two primary goals:
Enable the delivery of accurate, resilient PNT information to serve as a complement and backup to GPS.
Make additional low-band spectrum available for 5G deployment through partnerships with one or more mobile network operators.
She emphasized that this partnership model is economically viable and would make terrestrial PNT widely available without requiring the costly buildout of a separate, PNT-specific network infrastructure.
Gregory also summarized key findings from technical and economic studies that NextNav has submitted into the record:
Interference: 5G operations can coexist with unlicensed Part 15 devices in the 902-928 MHz band without causing unacceptable levels of interference. Unlicensed devices can continue to operate across the entire band.
Cost-Benefit Analysis: The proposed band optimization would impose zero cost on unlicensed users and minimal costs on tolling operations, while generating benefits estimated in the tens of billions of dollars.
Tolling Coexistence: Licensed tolling operations can coexist with the proposed 5G operations. Crucially, the plan would not require the retuning or replacement of consumer toll transponders. For the limited number of toll readers that may require retuning, NextNav has committed to providing reasonable accommodations, including financial and technical support, to ensure a smooth transition.
The meeting concluded with NextNav reiterating its call for the FCC to promptly issue a Notice of Proposed Rulemaking to advance its proposal.
Source: [NOTICE OF EXPARTE, NextNav Inc., https://www.fcc.gov/ecfs/document/108140782523233/1]
Space Exploration Holdings, LLC
Proceeding(s): 25-201
Date of Meeting: August 12, 2025
Date Disseminated: August 14, 2025
Participants:
Space Exploration Holdings, LLC (SpaceX): Jameson Dempsey, David Goldstein, Joe McMichael, and Joe Bissonnette
Federal Communications Commission (FCC) Space Bureau: Jay Schwarz, Jennifer Gilsenan, Stephen Duall, Gregory Coutros, Jon Markman, and Jeanine Poltronieri
Summary of Discussion:
Representatives from SpaceX met with the FCC's Space Bureau staff to discuss significant space sustainability concerns related to AST SpaceMobile's proposed satellite constellation, specifically focusing on deficiencies in AST's Orbital Debris Assessment Report (ODAR).
The main points of discussion were:
Unconventional Deorbiting Plan: SpaceX expressed concern over AST's proposed method for deorbiting its spacecraft. AST plans to have the satellites tumble during deorbit but intends to "detumble" them to perform collision avoidance maneuvers. SpaceX argued that AST has failed to provide any operational details or analysis to demonstrate that this approach is feasible or that it does not increase collision risks.
Withholding of Critical Data: SpaceX strongly objected to AST's repeated requests for confidential treatment of information necessary to evaluate the constellation's safety. Specifically, AST is seeking to withhold the "input data for calculating the cross-section area used for determining the spacecraft's orbital lifetime," which was data the Space Bureau had directly requested.
Inability to Verify Calculations: SpaceX noted that while AST has provided a figure for the cross-sectional area in the unredacted portion of its ODAR, SpaceX has been unable to replicate AST's orbital lifetime calculations using any of the provided figures. This suggests the Space Bureau staff encountered the same issue, prompting their request for the input data.
Proposed Compromise: AST claims that revealing the input data (component shapes and locations) would allow competitors to deduce proprietary satellite designs. SpaceX stated it has no interest in deducing designs but is focused on verifying the safety profile. As a solution, SpaceX proposed that if AST is permitted to keep the granular inputs confidential, it should be required to publicly state the exact value of the cross-sectional area used in its ODAR calculations. This would allow SpaceX and other parties to properly assess the orbital debris analysis while preserving AST's claimed proprietary information.
Source: [NOTICE OF EXPARTE, Space Exploration Holdings, LLC, https://www.fcc.gov/ecfs/document/10814018178481/1]