On The Record: SpaceX's Post-Election-Day Regulatory Strategy

An examination of 53 SpaceX filings on the FCC's ECFS reveals a campaign to reshape satellite spectrum policy, challenge incumbent operators, and accelerate the deployment of next-generation services.

Jul 06, 2025

Executive Summary

Since Election Day 2024, Space Exploration Holdings, LLC (SpaceX) has engaged in a high-tempo, multi-front regulatory campaign characterized by a dual strategy: systematically modernizing foundational rules to favor its non-geostationary orbit (NGSO) satellite model and aggressively challenging incumbent operators for access to valuable mid-band spectrum. An analysis of 53 filings between November 19, 2024, and July 02, 2025, reveals a clear progression from broad policy advocacy to highly targeted, competitive assaults designed to reshape the satellite services landscape. The company's efforts have centered on modernizing GSO-NGSO sharing rules in the 12 GHz band, streamlining launch communications in the S-band, and methodically expanding its global footprint for Supplemental Coverage from Space (SCS).

Initial efforts to reform what SpaceX terms "antiquated" rules, such as equivalent power flux-density (EPFD) limits, quickly evolved into a sustained campaign to dislodge competitors from key spectrum bands. EchoStar/DISH emerged as the primary target, with SpaceX waging a coordinated, multi-proceeding assault on its holdings in the 2 GHz/AWS-4 bands, accusing the company of "warehousing" prime mid-band spectrum and failing to meet its service obligations. Similar, though less intense, arguments were levied against Globalstar in the 1.6/2.4 GHz band and Viasat across several dockets. This "spectrum warehousing" narrative has become a cornerstone of SpaceX's strategy to create new market entry points for its services.

SpaceX consistently frames its policy objectives through the lens of national interest, arguing that its proposals are essential to "maintain American leadership in space," "win the race to 6G," and prevent foreign-licensed systems from gaining a competitive advantage. This narrative underpins a broader push for a "fast, flexible, and efficient regulatory framework," including light-licensing for frontier millimeter-wave bands and risk-informed regulatory fees based on orbital altitude—proposals that align directly with its high-volume, low-altitude business model. The pattern of activity demonstrates an aggressive regulatory posture aimed at fundamentally altering the competitive dynamics of the satellite industry.

Detailed Review

In the months following the 2024 election, SpaceX's engagement with the FCC painted a picture of a company intent on rewriting the rules of the satellite industry to match the pace of its technological and operational ambitions. The company’s filings reveal direct, data-driven challenges against its chief competitors.

The initial phase of this campaign, in late 2024, focused on clearing regulatory underbrush. A November 19 submission in the GSO-NGSO sharing proceeding argued that the time had come to update "antiquated equivalent power flux-density ('EPFD') limits for the new space age."1(to view source docs in the citations, start a no-obligation trial at docket-rocket.io) This filing, aimed at legacy GSO operators like Viasat and EchoStar, contended that their reliance on outdated protection metrics was "drastically limiting the level of broadband service that can be provided to Americans," an argument SpaceX reiterated in a December ex parte.2 In parallel, SpaceX advocated for streamlining launch communications, pushing for a "common licensing framework for launch and space operations under Part 26" to simplify access to critical S-band frequencies and arguing against what it saw as "overly conservative" PFD values proposed by NTIA.3

The Company is also engaged in advocacy of its Supplemental Coverage from Space (SCS) strategy. In a series of nearly identical letters, SpaceX notified the Commission of its intention to initiate SCS services in New Zealand, Australia, and Japan, leveraging partnerships with local mobile network operators One NZ and Telstra.4 The core argument in each filing was the same: because its partner is the sole licensee in the specified bands (e.g., the 2600 MHz mobile band in Australia), the potential for harmful interference is eliminated. This template-based approach, framed as supporting the "Commission's vision to lead the way for the global deployment of SCS," demonstrated an efficient, scalable model for international expansion that would soon face challenges from incumbents.

As 2025 began, SpaceX's regulatory posture shifted from foundational to confrontational. The company vigorously defended its SCS framework against a Petition for Reconsideration from Viasat. In a January filing, SpaceX asserted that "having failed to deploy its own direct-to-device service, Viasat is now trying to make sure Americans cannot benefit from any other operator."5 This defense broadened into a recurring theme: positioning legacy operators as obstructionists. A subsequent letter in February accused Viasat and “its front group the Mobile Satellite Service Association (“MSSA”)" of attempting to block life-saving SCS services after "decades of warehousing prime mid-band spectrum."6

This "spectrum warehousing" narrative became the spear tip of a new offensive. In January, SpaceX leveraged the proposed SES/Intelsat merger to argue for opening 200 MHz of the upper C-band (4.0-4.2 GHz) for shared use among multiple next-generation systems, explicitly to prevent a duopoly and foster competition.7 By March, the company had turned its attention to Globalstar, demanding the FCC dismiss its application for a new system in the 1.6/2.4 GHz band. SpaceX argued that accepting the application would violate the Administrative Procedure Act by failing to treat "similarly situated parties similarly," citing the FCC's prior dismissal of SpaceX's own application pending a rulemaking for the "long-fallow" band.8

However, the most intense and sustained front in this campaign opened against EchoStar. A March 21 letter planted the flag, claiming EchoStar's market access for the 2 GHz band had "expired years ago" due to its failure to provide service.9 This filing initiated an escalating, multi-proceeding assault that would dominate the company's advocacy for the next several months. Throughout this offensive, SpaceX continued its operational cadence, filing for SCS service in Chile and Peru, and pushing for streamlined, “five-to-ten day” coordination windows for launch spectrum.10

From April through July, the campaign against EchoStar intensified dramatically, becoming a case study in coordinated, multi-docket advocacy. SpaceX supplemented its legal arguments with technical claims, stating in an April 15 letter that "new data confirms what most people already suspected—EchoStar barely uses the AWS-4 band."11 Filings in proceedings 22-212, 25-173, and RM-11976 built a comprehensive record, alleging EchoStar had left "95-99% of the AWS-4 / 2 GHz band vacant" and engaged in a "thirteen-year long-game of misdirection designed to allow it to squat on spectrum."12 SpaceX argued that EchoStar's licenses had automatically terminated under Commission rules and urged the FCC to "swiftly act to open the 2 GHz band so that new entrants can finally bring the American public the satellite services that EchoStar has denied them for years."13

This targeted attack was part of a larger, more comprehensive vision for regulatory reform. In the Chairman's "Delete, Delete, Delete" proceeding, SpaceX advocated for a "first-principles approach to regulatory reform," including self-coordinated "light licensing" in millimeter-wave bands.14 In the regulatory fee proceeding, it argued against a fee structure linear to constellation size, calling it "arbitrary, punitive, [and] patently unfair," instead proposing a risk-informed model based on operating altitude—a metric that benefits its low-altitude system.15

Simultaneously, SpaceX began to proactively shape the landscape for future services. In May, it urged the Commission to build a "robust pipeline of satellite spectrum" by reallocating the 12.7-13.25 GHz band for FSS downlinks and opening up "frontier" V-band and W-band spectrum for new NGSO use.16 This forward-looking advocacy, combined with its aggressive challenges to incumbents, illustrates a strategy that is both offensive and defensive. The company is not merely seeking to operate within the current framework; it is actively using the regulatory process to create a framework that is better suited to its technology and more open to its competitive entry.

A final ex parte on July 2 encapsulated the entire campaign's urgency, warning that by failing to open underutilized mid-band MSS spectrum in the 2 GHz and 1.6/2.4 GHz bands, the Commission "risks ceding leadership over mid-band frequencies to non-U.S. licensed systems."17

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