Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

)
ICFS File Nos.:
)
Application of: )
SAT-MOD-20250612-[____]
)
SAT-LOA-20200413-00034
AST & Science, LLC )
SAT-AMD-20200727-00088
)
SAT-AMD-20201028-00126
Application for Modification of License to )
SAT-AMD-20230717-00172
Launch and Operate the SpaceMobile )
SAT-AMD-20240311-00053
Non-Geostationary Orbit Satellite System )
)
Call Sign S3065
)

APPLICATION FOR MODIFICATION OF LICENSE TO LAUNCH AND OPERATE

THE SPACEMOBILE NON-GEOSTATIONARY ORBIT SATELLITE SYSTEM

Jennifer A. Manner Timothy L. Bransford

Senior Vice President, Regulatory Affairs Denise S. Wood
and International Strategy Kathryne C. Dickerson
Phuong N. Pham Greenberg Traurig, LLP
Vice President, Regulatory Affairs 2101 L Street N.W., Suite 1000
AST SpaceMobile, Inc. Washington, D.C. 20037
(202) 331-3100
(202) 331-3101 (Fax)
timothy.bransford@gtlaw.com

Counsel to AST & Science, LLC

 Table of Contents

I. INTRODUCTION .............................................................................................................. 1

A. Background ......................................................................................................................... 4

II. OVERVIEW OF THE MODIFICATION .......................................................................... 7

A. Updated Bluebird Satellite Technical Parameters .............................................................. 8

B. Updated Frequency Information ......................................................................................... 8

C. Service Coverage Areas .................................................................................................... 12

D. Launch Schedule ............................................................................................................... 12

III. SCS ENTRY CRITERIA .................................................................................................. 12

A. Certifications of Substantial Compliance ......................................................................... 12

B. GIA Waiver Request ......................................................................................................... 13

IV. GRANT OF THE APPLICATION WILL SERVE THE PUBLIC INTEREST BY

FACILITATING EMERGENCY COMMUNICATIONS, PROMOTING U.S.
LEADERSHIP IN COMMUNICATIONS, AND FOSTERING INNOVATIVE AND
EFFICIENT USE OF SPECTRUM .................................................................................. 21

V. ELIGIBILITY, OPERATIONAL, ITU, AND OWNERSHIP REQUIREMENTS ......... 24

VI. CONCLUSION ................................................................................................................. 24

i
 Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

)
) ICFS File Nos.:
)
In the Matter of:
) SAT-MOD-20250612-[____]
) SAT-LOA-20200413-00034
AST & Science, LLC
) SAT-AMD-20200727-00088
) SAT-AMD-20201028-00126
Application for Modification of License to
) SAT-AMD-20230717-00172
Launch and Operate the SpaceMobile
) SAT-AMD-20240311-00053
Non-Geostationary Orbit Satellite System
)
) Call Sign S3065

APPLICATION FOR MODIFICATION OF LICENSE TO LAUNCH AND OPERATE

THE SPACEMOBILE NON-GEOSTATIONARY ORBIT SATELLITE SYSTEM

I. INTRODUCTION

AST & Science, LLC (“AST SpaceMobile”), in accordance with Part 25 of the rules 1 of

the Federal Communications Commission (“FCC” or “Commission”), hereby files this

application (the “Application”) to request modification of its existing authorization to launch and

operate a constellation of non-geostationary orbit (“NGSO”) satellites in low-Earth orbit

(“LEO”) (the “SpaceMobile System”). 2 Specifically, AST SpaceMobile seeks FCC authority to

enable the provision of Supplemental Coverage from Space (“SCS”) to unmodified mobile

1
See 47 C.F.R. §§ 25.117, 25.125.
2
See AST & Science LLC, Application to Launch and Operate a Non-Geostationary Orbit V-band System, Call Sign
S3065, Order and Authorization, FCC Rcd 8558 (2024) (“V-band Grant”). Additionally, pursuant to Section 25.116
of the FCC’s rules, AST SpaceMobile seeks to amend its partially deferred application to launch and operate the
SpaceMobile System by including the changes proposed herein. See id. at para. 27; see also 47 C.F.R. § 25.116.

1
devices in the United States, using 700 MHz and 800 MHz spectrum consistent with the

secondary Mobile-Satellite Service (“MSS”) allocations. 3 The Application also:

1. adjusts the technical parameters, including the orbital altitudes and

inclinations, of AST SpaceMobile’s planned 248-satellite constellation;

and

2. updates the locations AST SpaceMobile will use for off-nominal

Telemetry, Tracking, and Command (“TT&C”), transmitting to and

from earth stations located outside the United States. 4

AST SpaceMobile applauds the Commission for its commitment to advancing America’s

leadership in space under the leadership of Chairman Carr, 5 and appreciates the recognition that

AST SpaceMobile is “at the forefront of an absolutely transformative trend in technology.” 6

Granting the Application will allow AST SpaceMobile to deploy its innovative satellite

constellation using terrestrial spectrum licensed to partners, AT&T Mobility LLC (“AT&T”),

3
47 C.F.R. § 2.106, Table of Frequency Allocations, non-federal footnote, NG33A (“NG33A: The secondary MSS
operations in the bands 614-652 MHz and 663-769 MHz, 775-799 MHz, and 805-806 MHz, 824-849 MHz and 869-
894 MHz, and 1850-1920 MHz and 1930-2000 MHz are limited to Supplemental Coverage from Space (SCS) and
are subject to the Commission’s SCS rules in part 25 of this chapter.”).
4
Also attached is a complete Form 312, Schedule S, updated ownership information and a Technical Statement,
including interference analyses and orbital debris mitigation information. AST SpaceMobile appreciates that the
grant of authority approving the launch and operation of the initial five (5) Bluebird spacecraft under Call Sign
S3065 deferred final action on a number of requests. For example, the Commission deferred action on AST
SpaceMobile’s request to operate additional satellites. V-band Grant at para. 5. To the extent necessary, AST
SpaceMobile requests that the Commission resolve issues deferred in the V-band Grant pursuant to the captioned
amendment applications above.
5
See Office of Chairman Brendan Carr, Chairman Carr Highlights Wins Delivered During First 100 Days, FCC
(April 29, 2025), https://docs.fcc.gov/public/attachments/DOC-411127A1.pdf; Office of Chairman Brendan Carr,
FCC Chairman Carr Announces Early Wins at Launch of Satellite Week, FCC (March 10, 2025),
https://docs.fcc.gov/public/attachments/DOC-410075A1.pdf (“From expanding connectivity, to strengthening
national security, our space industry is delivering real results for the country. For my part, I want America’s satellite
operators and space launch teams to know that the FCC will prioritize your work and partner with you to find
solutions. To expand U.S. leadership in space, I will focus the FCC’s work on speed, simplification, and ensuring
you have the spectrum resources necessary to fuel this sector’s growth.”).
6
@AST_SpaceMobile, X.com (April 28, 2025, 2:00 PM),
https://x.com/AST_SpaceMobile/status/1916915326152823229.

2
and Verizon Communications, Inc. (“Verizon”), to deliver integral SCS broadband services to

government users, businesses, and consumers, without harmful interference to co-channel

terrestrial incumbent spectrum operators, given the satellites’ ability to shape and contour beams.

Because the required chipsets are already in smartphones, consumers will immediately be able to

receive the benefits of SCS broadband services once the constellation is operational. AST

SpaceMobile’s satellite technology is designed to protect co-channel and adjacent channel

licensed operators. AST SpaceMobile’s ability to shape and contour beams enables

comprehensive protection of co-channel terrestrial incumbent spectrum operators. To ensure

these broadband services are available expeditiously, and to enable AST SpaceMobile to adhere

to its launch schedule, AST SpaceMobile respectfully requests FCC grant of launch authority for

its proposed satellites by no later than August 1, 2025. 7 Receipt of U.S. authorization is also a

prerequisite to obtaining authorization in the foreign jurisdictions in which AST SpaceMobile

will seek to provide SCS. 8 By promptly granting the Application, the Commission will advance

the public interest by helping close the connectivity gap in the United States and globally,

including for first responders, consumers, and businesses. 9

7
Concurrently with or shortly after this filing, AST SpaceMobile is also submitting a request for special temporary
authority to launch and test its proposed satellites while the Commission reviews this Application.
8
In re Single Network Future: Supplemental Coverage from Space, Space Innovation, GN Docket No. 23-65, IB
Docket No. 22-271, Report and Order and Further Notice of Proposed Rulemaking, 39 FCC Rcd 2622, 2722-
2723(2024) (“SCS R&O”) (“(1) In order to be authorized to deploy a satellite or system with the capability to
operate outside the United States, an applicant must first obtain a U.S. space station license that covers all of the
frequencies on the satellite, including those that they propose to operate on with U.S. earth stations, as well as those
to be used internationally. … (2) Then, prior to conducting any communications with earth stations outside the
United States, the space station licensee must ensure that all of its operations are duly authorized by the country in
which such communications will occur, and that it will satisfy all terms and conditions of any foreign license or
authorization, including but not limited to any transmit power, out of band emission, geographic, or other limits.”).
9
Addressable Market, AST SPACEMOBILE, https://ast-science.com/spacemobile-network/addressable-market/ (last
visited May 27, 2025).

3
 A. Background

AST SpaceMobile is advancing U.S. leadership in space-based technologies by building

an innovative, space-based cellular broadband network that will be used to provide direct-to-

device (“D2D”) services on unmodified mobile devices, including 4G LTE, and 5G devices and

beyond. AST SpaceMobile is headquartered in Midland, Texas where it operates a state-of-the-

art, vertically integrated, 185,000 square foot manufacturing facility. 10 Final assembly,

integration, and testing of its satellites are conducted in Texas, and the majority of its employees

reside in the United States. As Chairman Carr recently remarked during his visit to Midland,

AST SpaceMobile’s “high-tech production facility” is helping to “grow our economy, [ ] create

jobs, and importantly . . . secure our national defense.” 11

Having partnered with numerous mobile network operators and telecommunications

companies, including AT&T and Verizon, secured strategic investments from U.S. companies,

and entered into contracts with key U.S. agencies for its services, AST SpaceMobile is well-

positioned to bring D2D services to users across the United States and globally. 12

10
AST SpaceMobile also has a network operations facility in Lanham, Maryland.
11
@BrendanCarrFCC, X.com (Apr. 23, 2025, 5:14pm),
https://x.com/brendancarrfcc/status/1915152277377044685?s=46. See also ICYMI: Chairman Cruz, Chairman Carr
Toured AST SpaceMobile Facilities, TED CRUZ (April 24, 2025), https://www.cruz.senate.gov/newsroom/press-
releases/icymi-chairman-cruz-chairman-carr-toured-ast-spacemobile-facilities (“AST SpaceMobile is building the
future of global connectivity right here in Midland, one of the world’s most innovative and entrepreneurial cities.
They’re building the largest low-earth-orbit satellites in history, and are well on the way to being able to provide
high-speed broadband to every cell phone in America. Texas is leading the United States, and the world, into the
next frontier of broadband and communications.”).
12
See Strategic Partners, AST SPACEMOBILE, https://ast-science.com/company/strategic-partners/ (last visited
March 13, 2025); AST SpaceMobile Secures $43 Million Contract in Support of U.S. Space Development Agency
Through Prime Contractor, BUSINESSWIRE (Feb. 26, 2025),
https://www.businesswire.com/news/home/20250226892736/en/AST-SpaceMobile-Secures-%2443-Million-
Contract-in-Support-of-U.S.-Space-Development-Agency-Through-Prime-Contractor.

4
 In 2022, AST SpaceMobile launched its first prototype satellite—BlueWalker 3 (“BW3”)

—to test and demonstrate D2D technology. 13 BW3 deployed the largest commercial phased

array antenna in LEO, 14 and AST SpaceMobile achieved multiple historical breakthroughs in

testing, including completing the first-ever space-based calls to unmodified smartphones 15 and

connectivity speeds of more than 20 megabits per second per 5 MHz. 16

AST SpaceMobile built on the success of BW3 with the launch of its first five

commercial “Bluebird” satellites (“BB1s”), pursuant to the V-band Grant. 17 In conjunction with

the V-band Grant, and pursuant to experimental authorizations issued by the Commission,18 AST

SpaceMobile has continued to demonstrate the feasibility of its planned services. Recently,

AT&T and AST SpaceMobile successfully completed a video call by satellite over AT&T

spectrum using an unmodified smartphone and the BB1s. 19 As AT&T’s Chief Operating Officer

remarked, “We are striving to provide everyone, from urban centers to remote areas, with access

13
BlueWalker 3, AST SPACEMOBILE, https://ast-science.com/spacemobile-network/bluewalker-3/ (last visited May
27, 2025).
14
David Todd, BlueWalker 3 Satellite Unfurls Largest Ever Commercial Phased Array In Orbit, SERADATA (Nov.
15, 2022), https://www.seradata.com/bluewalker-3-satellite-unfurls-largest-ever-commercial-phased-array-in-orbit/.
15
AST SpaceMobile Makes History in Cellular Connectivity, Completing the First-Ever Space-Based Voice Call
Using Everyday Unmodified Smartphones, AST SPACEMOBILE (April 25, 2023), https://ast-
science.com/2023/04/25/ast-spacemobile-makes-history-in-cellular-connectivity-completing-the-first-ever-space-
based-voice-call-using-everyday-unmodified-smartphones/.
16
Rachel Jewett, AST SpaceMobile Reports 5G Broadband Speeds Via Satellite, VIASATELLITE (Sept. 19, 2023),
https://www.satellitetoday.com/connectivity/2023/09/19/ast-spacemobile-reports-5g-broadband-speeds-via-satellite/.
17
See V-band Grant. See also AST SpaceMobile Successfully Completes Unfolding of First five Commercial
Satellites in Low Earth Orbit, BUSINESSWIRE (Oct. 25, 2024),
https://www.businesswire.com/news/home/20241025345390/en/AST-SpaceMobile-Successfully-Completes-
Unfolding-of-First-Five-Commercial-Satellites-in-Low-Earth-Orbit.
18
OET File No. 2053-EX-ST-2024. See also AST SpaceMobile Announces FCC Grant of Special Temporary
Authority (STA) In the United States with Strategic Partners AT&T and Verizon, BUSINESSWIRE (Jan. 30, 2025),
https://www.businesswire.com/news/home/20250130886840/en/ (“During 2024, AST SpaceMobile secured
additional strategic investment from AT&T, Verizon, Google and Vodafone, and new contract awards with the
United States Government.”).
19
True Blue Connection: AT&T and AST SpaceMobile Take Connectivity to New Heights, AT&T (Feb. 24, 2025),
https://about.att.com/story/2025/ast-spacemobile-video-call.html.

5
to reliable connectivity. This is about more than technology. It’s about empowering people and

communities everywhere.” 20

AST SpaceMobile and Verizon have also pushed the boundaries of what can be done

with mobile devices by successfully completing a live video call between two mobile devices—

one connected via satellite and the other connected via Verizon’s terrestrial network. 21 “This

breakthrough marks a new era in cellular to satellite connectivity in the United States . . . .

Adding this layer of ability . . . will only enhance the reliability of our customers’ connectivity

and communication experience, “ said Hans Vestberg, Chairman and CEO of Verizon. 22

As announced in its recent earnings call, AST SpaceMobile requires grant of this

application this summer as it moves forward with the manufacture, launch, and operation of its

satellites. Most notably, AST SpaceMobile anticipates orbital launches every one to two months

on average during 2025 and 2026, with the first Block 2 BlueBird (“BB2”) satellite, FM1,

expected to ship to the launch provider during the second quarter of 2025 for a launch scheduled

in July 2025, thus commencing an accelerated launch campaign of more than 60 BB2 satellites

set to launch through the end of next year. 23

AST SpaceMobile is also on track with the procurement of components and materials

needed to complete fully assembled microns and phased arrays for over 50 satellites, and

complete 40 fully integrated and assembled BB2 satellites. 24 AST SpaceMobile expects that

satellite manufacturing will reach a cadence of six satellites per month during 2025, with phased

20
Id.
21
Verizon Completes Its First Satellite to Cellular Enabled Video Call with AST SpaceMobile BlueBird 2, VERIZON
(Feb. 24, 2025), https://www.verizon.com/about/news/verizon-ast-spacemobile-bluebird-2.
22
Id.
23
See AST SpaceMobile, Inc., Quarterly Report (Form 10-Q), p. 23 (May 12, 2025) (“AST SpaceMobile 10-Q”).
24
See id. at p. 24.

6
array equivalent cadence reaching the target during the third quarter of 2025. These

manufacturing and orbital launch schedules support continuous cellular broadband coverage

goals in key markets such as the United States, Europe, Japan, the U.S. Government and other

strategic markets during 2026.

II. OVERVIEW OF THE MODIFICATION

The SpaceMobile System will connect directly to partner mobile service provider

networks to allow consumers to access space-based cellular broadband connectivity using

unmodified mobile devices. The V-band Grant provided a critical first step, permitting

deployment of the first five commercial BB1 satellites of the overall anticipated 248-satellite

constellation. The V-band Grant authorized operation of feeder links and nominal TT&C

operations using frequencies in the 37.5-42 GHz (space-to-Earth), 47.2-50.2 GHz (Earth-to-

space), and 50.4-51.4 GHz (Earth-to-space) bands. The V-band Grant also granted authority to

conduct TT&C with the BB1s in the 430-440 MHz (space-to-Earth and Earth-to-space), 2025-

2110 MHz (Earth-to-space), and 2200-2290 MHz (space-to-Earth) bands. 25 The Commission

deferred consideration of AST SpaceMobile’s request to deploy and operate the remaining 243

satellites in its proposed constellation as well as its request to operate on any additional

frequencies, including any bands allocated to terrestrial services that it would ultimately seek to

use for the provision of SCS. 26

With this Application, AST SpaceMobile provides the Commission with the information

required under the SCS R&O and the relevant Part 25 rules, along with requisite waiver

justifications to support grant of authority for the revised technical parameters of the complete

25
V-band Grant at para. 1.
26
Id.

7
248-satellite SpaceMobile System and corresponding direct-to-cell service links on AT&T and

Verizon frequencies allocated for the provision of SCS, as further described below. 27

A. Updated Bluebird Satellite Technical Parameters

AST SpaceMobile provides updates to the technical parameters of its planned

constellation, including orbital altitudes and inclinations, as further reflected in the Technical

Statement and Schedule S. AST SpaceMobile notes that it has lowered the orbital altitudes of all

satellites in its planned constellation to altitudes of 690 km or below. This is consistent with the

FCC’s recommendation, made when granting a previous application, that AST SpaceMobile

“make a good faith effort to adopt or work towards . . . choos[ing] orbital elevations of ~700 km

or lower when feasible.” 28

B. Updated Frequency Information

In this section, AST SpaceMobile presents a comprehensive overview of the frequencies

upon which its planned constellation will be capable of operating, both inside and outside the

United States, and updates its Feeder Link and Service Link operations within the United States.

The frequency bands in the following Table 1 reflect all gateway/feeder link and TT&C

frequencies in which AST SpaceMobile’s planned constellation will be capable of operating.

27
SCS R&O at para. 28.
28
V-band Grant at paras. 17, 33.

8
 Domestic and International Capabilities
Frequencies Use Direction
37.5-42.0 GHz Gateway/Feeder Links, Routine space-to-Earth
TT&C
47.2-50.2 GHz Gateway/Feeder Links, Routine Earth-to-space
TT&C
50.4-51.4 GHz Gateway/Feeder Links, Routine Earth-to-space
TT&C
Additional Non-U.S. Capabilities 29
Frequencies Use Direction
400-410 MHz Non-U.S. Off-Nominal TT&C space-to-Earth and
and Orbit-Raising Maneuvers Earth-to-space
430-440 MHz Non-U.S. Emergency TT&C space-to-Earth and
Communications Earth-to-space
45.5-47.0 GHz Non-U.S. Gateway/Feeder Links Earth-to-space
2025-2110 MHz Non-U.S. Off-Nominal TT&C Earth-to-space
and Orbit-Raising Maneuvers
2200-2290 MHz Non-U.S. Off-Nominal TT&C space-to-Earth
and Orbit-Raising Maneuvers
Table 1 – Gateway/Feeder Link and TT&C Frequencies

In the V-band Grant, the FCC concluded that AST SpaceMobile’s feeder links and

nominal TT&C operations in the V-band could be classified as a fixed satellite service.

Accordingly, AST SpaceMobile’s use of V-band frequencies for feeder links and nominal TT&C

is consistent with the U.S. Table of Frequency Allocations and international allocations. 30 TT&C

operations will be conducted in the S- and UHF bands outside the United States through third-

party ground station service providers. The Technical Statement further describes the frequencies

29
To be used in accordance with applicable regulations in relevant jurisdictions. See Attachment A, Technical
Statement, Annex A for locations of third-party international gateway operations locations.
30
The 40-42 GHz portion of the V-band is currently allocated both in the U.S. Table of Frequency Allocations (the
“Table”) and internationally for fixed satellite service (“FSS”), and parts of the band are shared with fixed service,
mobile service, MSS, broadcasting service, and broadcasting-satellite service. AST SpaceMobile confirms that it
will take all practicable steps to protect radio astronomy observations in the adjacent bands from harmful
interference. The 47.2-48.2 GHz portion of the V-band is currently allocated in the Table for FSS, fixed service, and
mobile service, limited to non-Federal stations, and the 48.2-50.2 GHz portion is allocated for these same services
for both Federal and non-Federal stations. The 50.4-51.4 GHz (Earth-to-space) band is allocated to FSS, fixed
service, and mobile service, and MSS for both Federal and non-Federal stations in the United States and for those
same services internationally, with MSS allocated on a secondary basis.

9
reflecting the entire global capabilities of the SpaceMobile System, including the global TT&C

Ground Stations and frequencies. 31

Table 2 reflects all Service Link frequencies for which AST SpaceMobile currently seeks

authorization in the United States and the additional service link frequencies in which the

planned constellation will be capable of operating globally, subject to authority granted by, and

compliance with applicable regulations in, relevant jurisdictions. Pursuant to Section

2.106(d)(33)(i) of the Commission’s rules, each of the U.S. service link frequency bands

identified below are explicitly exempt from processing rounds or first-come, first-served

procedures. 32 Additionally, AST SpaceMobile acknowledges that the non-U.S. service link

frequency bands identified below will not conform with the International Table of Frequency

Allocations and will therefore be governed by ITU Radio Regulation No. 4.4. 33

31
See Attachment A, Technical Statement.
32
47 C.F.R. § 2.106(d)(33)(i); see also SCS R&O at para. 28 (listing bands available for SCS, specifically: 614-652
MHz and 663-698 MHz; 698-769 MHz, 775 MHz-799 MHz, and 805-806 MHz; 824-849 MHz and 869-894 MHz;
1850-1915 MHz and 1930-1995 MHz; and 1915-1920 MHz and 1995-2000 MHz).
33
SCS R&O at para. 224 (“… [U]nder the SCS framework we adopt today, SCS will be authorized pursuant to a
secondary MSS allocation in the U.S. Table. Although the operations will be consistent with the U.S. Table, these
operations will not conform with the International Table, and resolution of cross-border interference will be
governed by ITU Radio Regulation No. 4.4.”).

10
 U.S. Capabilities
Frequencies Use Direction
698-716 MHz Service Links Earth-to-space
728-746 MHz Service Links space-to-Earth
824-849 MHz Service Links Earth-to-space
869-894 MHz Service Links space-to-Earth
Global Capabilities 34
Frequencies Use Direction
663 -748 MHz Service Links Earth-to-space
777 -798 MHz
807 -862 MHz
880 -915 MHz
617 -652 MHz Service Links space-to-Earth
728 -821 MHz
852 -894 MHz
902 -960 MHz
Table 2 – Service Link Operations

Submitted herewith are detailed interference analyses and associated link budgets

showing that AST SpaceMobile’s requested operations will not cause harmful interference to

stations operating in accordance with the ITU Radio Regulations. 35 AST SpaceMobile also

confirms that it will “ensure that all of its operations are duly authorized by the country in which

such communications will occur, and that it will satisfy all terms and conditions of any foreign

license or authorization, including but not limited to any transmit power, out of band emission,

geographic, or other limits.” 36

34
To be used in accordance with applicable regulations in relevant jurisdictions. See SCS R&O at para. 50 (“As a
supplemental service, SCS satellite operations are inherently secondary to the terrestrial operations in the bands, and
under the rules we adopt herein, SCS access to the relevant bands requires permission of the relevant terrestrial
licensees through the use of our leasing framework.”).
35
Id. at para. 226 (“SCS applicants seeking to use spectrum on a non-conforming basis with respect to the
International Table will be required to provide detailed interference analyses and associated link budgets showing
that requested operations will not cause harmful interference to stations operating in accordance with the ITU Radio
Regulations. These analyses will also be used as supporting documentation along with the ITU registration materials
to support the Commission’s representation—as the notifying administration to the ITU—that any such operations
will not cause harmful interference.”).
36
Id. at para. 234.

11
 C. Service Coverage Areas

As further described below and in the Technical Statement, the SpaceMobile System will

provide direct-to-cell broadband SCS services within the contiguous United States (“CONUS”)

and Hawaii (using AT&T and Verizon Spectrum). 37 Additionally, as of the date of this filing,

AST SpaceMobile has conducted, or expects to commence, testing for SCS in collaboration with

its terrestrial wireless mobile partners in international jurisdictions, including the United

Kingdom, Japan, Canada, and Türkiye. 38

D. Launch Schedule

AST SpaceMobile intends to begin launching additional satellites in its SpaceMobile

System in July 2025, with the exact date dependent upon launch operator availability and

considerations such as weather. AST SpaceMobile anticipates orbital launches every one to two

months on average during 2025 and 2026, with the first BB2 satellite, FM1, expected to ship in

the second quarter of 2025 for a launch scheduled in July 2025, thus commencing an accelerated

launch campaign of more than 60 BB2 satellites set to launch through the end of next year. 39

III. SCS ENTRY CRITERIA

A. Certifications of Substantial Compliance

Consistent with the Commission’s SCS entry criteria, 40 AST SpaceMobile:

37
This application seeks authorization to provide SCS in CONUS and Hawaii using AT&T Spectrum and Verizon
Spectrum. AST SpaceMobile may seek additional authority for other geographically independent areas (“GIAs”) in
the future.
See ELS File Nos. 0655-EX-ST-2025 (Canada), 0369-EX-ST-2025 (Japan), and 2224-EX-ST-2024 (UK), 2173-
38

EX-ST-2024 (Türkiye).
39
See AST SpaceMobile 10-Q at p. 23 (May 12, 2025).
40
See 47 C.F.R. § 25.125(a).

12
 (i) holds a five-satellite NGSO license and is seeking to modify the existing NGSO

license to authorize launch and operation of its planned 248-satellite constellation

for the provision of SCS services; 41 and

(ii) has lease arrangements with AT&T and Verizon to access their respective

spectrum in the 700 MHz and 800 MHz bands within CONUS and Hawaii.

Accordingly, pursuant to Section 25.125(b)(1) of the Commission’s rules, 42 AST

SpaceMobile certifies that:

(i) notifications of spectrum manager leases authorizing AST SpaceMobile’s SCS

use of AT&T’s 800 MHz (A and B blocks) and Lower 700 MHz (A, B and C

blocks) spectrum (“AT&T Spectrum”), 43 as well as Verizon’s 800 MHz (A and

B blocks) spectrum (“Verizon Spectrum”), 44 are on file with the Commission;

(ii) AST SpaceMobile seeks modification of authority for SCS use of AT&T and

Verizon Spectrum in the same geographic areas covered in the CONUS and

Hawaii GIAs; and

(iii) SCS earth stations using AT&T or Verizon Spectrum will qualify as “licensed by

rule” earth stations under Section 25.115(q) of the FCC’s rules.

B. GIA Waiver Request

AST SpaceMobile seeks to provide SCS services to its terrestrial wireless partners,

AT&T and Verizon, using the AT&T Spectrum and Verizon Spectrum for the CONUS GIA

41
See V-band Grant; 47 C.F.R. § 25.125(a).
42
See 47 C.F.R. § 25.125(b)(1).
43
See ULS File No. 0010538493(Lead Application), et al.
44
See ULS File No. 0011607666 (Lead Application), et al.

13
(“GIA 1”) and Hawaii GIA (“GIA 2”). 45 Through its lease agreements with these partners, AST

SpaceMobile will have access to spectrum covering a significant percentage of the geographic

area and population of CONUS and Hawaii. 46 Because AT&T and Verizon each holds all co-

channel licenses in the relevant bands in Hawaii, a waiver is not required for GIA 2.

Accordingly, pursuant to Sections 1.3 and 1.925 of the Commission’s rules, 47 AST

SpaceMobile respectfully requests waiver, for GIA 1, of the requirement that an SCS applicant

enter into lease agreements with one or more terrestrial wireless licenses that hold, collectively

or individually, 48 The Commission may waive its rules for good cause when “ 49 As

demonstrated below, good cause, including special circumstances, exists here to warrant a

waiver of the GIA Entry Requirement where, as the Commission expressly contemplated,

applicants demonstrate “ 50

1. Special Circumstances Support Waiver

AST SpaceMobile has entered into leasing arrangements with its terrestrial partners for

low-band spectrum covering a significant percentage of the geographic area and population of

CONUS. Given its more favorable propagation characteristics when compared to spectrum

above 1 GHz, spectrum below 1 GHz represents the ideal transmission medium for SCS service

45
47 C.F.R. § 25.103 (defining six geographically independent areas).
46
Although the SCS R&O contemplates coverage on a per frequency basis, AST SpaceMobile will achieve this
coverage by deploying on a combination of 700 MHz and 800 MHz spectrum held by AT&T and Verizon.
47
47 C.F.R. § § 1.3, 1.925.
48
47 C.F.R. § 25.125(a) (“An applicant for SCS space station authorization must … have a lease arrangement(s) …
with one or more terrestrial wireless licensee(s) that hold, collectively or individually, all co-channel licenses
throughout a GIA in a band identified in § 2.106(d)(33)(i) of this chapter.”).
49
Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
50
SCS R&O at para. 56.

14
links. 51 Thus, AST seeks waiver of the GIA Entry Requirement with respect to the 800 MHz

Cellular A and B blocks and the 700 MHz A, B, and C blocks. While limited nationwide low-

band spectrum exists under the control of a single entity, AST SpaceMobile worked with two

operators—Verizon and AT&T—two of the largest wireless carriers in the United States,

respectively, 52 to enable SCS across the majority of CONUS.

2. Good Cause Exists for Favorable Action on Waiver

There are overwhelming public interest benefits that support an expeditious grant of this

waiver request. Strict adherence to the GIA Entry Requirement would hinder deployment of SCS

service and the development of a healthy SCS ecosystem that involves a diverse group of mobile

network operators (“MNOs”), hardware manufacturers, and satellite operators. In contrast, grant

of the waiver would enhance competition in the emerging SCS marketplace and more effectively

implement the Commission’s stated overall policy goal of “propel[ing] the United States towards

a single network future that supports public safety, ubiquitous connectivity, technological

innovation, sharing of spectrum resources, and global leadership, to the benefit of all

Americans.” 53

These goals are also at the heart of AST SpaceMobile’s planned SCS services. First, AST

SpaceMobile’s SCS services will allow consumers, public safety officials, and others to access

51
Spectrum below 1 GHz propagates further and through atmospheric anomalies better than higher frequencies. See,
e.g., In re Policies Regarding Mobile Spectrum Holdings, Expanding the Economic and Innovation Opportunities of
Spectrum Through Incentive Auctions, WT Docket No. 12-269, GN Docket No. 12-268, Report and Order, 29 FCC
Rcd 6133, 6135 (2014) (“[N]ot all spectrum is created equal. Spectrum below 1 GHz has, compared to spectrum
above 1 GHz, distinct propagation advantages for network deployment over long distances, while also reaching deep
into buildings and urban canyons. High-band spectrum is more plentiful and possesses certain technical advantages
allowing for the transmission of large amounts of information. In this sense, spectrum below 1 GHz may be thought
of as ‘coverage’ spectrum, and high-band spectrum may be thought of as ‘capacity’ spectrum.”) (“Policies Order”).
52
Nathan Reiff, 10 Biggest Telecommunications (Telecom) Companies, INVESTOPEDIA (Nov. 19, 2024),
https://www.investopedia.com/articles/markets/030216/worlds-top-10-telecommunications-companies.asp.
53
Policies Order at para. 6.

15
space-based cellular broadband communications services even when the terrestrial cellular

network is not available, including during natural disasters and emergencies, from their

unmodified smart phones. Allowing AST SpaceMobile to deploy SCS services in those areas

where it does hold spectrum lease rights in GIA 1 would further the development of nascent SCS

technology, positively impacting the development of a vibrant SCS ecosystem. 54

Second, as the Commission continuously strives to make more flexible and intense use of

finite radio frequency resources, enabling AST SpaceMobile to use low-band spectrum to deliver

SCS services to millions of Americans, including the unserved or underserved, unambiguously

promotes the public interest. 55

Third, granting the waiver will ensure AST SpaceMobile, a U.S. company, is able to

deploy its innovative, made in America, first-of-its kind technology, furthering the United States’

position as the global leader in space. And doing so now is important because modern satellite

engineering requires iterative improvements. AST SpaceMobile has already learned much from

its early launches and expects to learn more from the FM1 satellite and additional launches later

this year—actually commencing service will allow AST SpaceMobile to continue to refine and

develop its ground-breaking satellites in the near term—an important means for the United States

to remain at the forefront of the 21st century space race.

54
See In re Extreme Networks Request for Waiver of Section 15.403 of the Commission’s Rules, ET Docket No. 23-
282, Order, DA 24-1215, para. 11 (rel. Dec. 5, 2024) (“Extreme Networks Order”) (finding that declining to grant a
requested waiver “may actually diminish the public benefit” of a planned service because consumers would lose
connectivity).
55
See, e.g., Review of the Commission’s Rules Governing the 896-901/935-940 MHz Band, WT Docket No. 17-200,
Notice of Inquiry, 32 FCC Rcd 6421 (2017) (seeking to pool and regroom certain 900 MHz spectrum licenses to
better enable contemporary applications and services).

16
 3. FCC Expressly Contemplated Waivers of SCS Entry Criteria

When it adopted the SCS rules, the Commission emphasized that it would follow a

“hybrid approach” and continue to “actively monitor the nascent SCS marketplace to consider

modifications and to address proposals that do not fit neatly within our framework by waiver. 56

The Commission further stated that its approach:

leav[es] the door open for other implementations to be approved by waiver. It

does not foreclose the ability for parties with proposals for providing SCS that do

not satisfy our framework from applying to the Commission and demonstrating

that they will not cause harmful interference under the proposed parameters

specific to their SCS operations. 57

Indeed, the Commission appears to have contemplated waivers of its GIA requirement

given that many of the bands it authorized for SCS have numerous licensees scattered across the

CONUS GIA. AT&T does not hold all licenses in the Lower 700 MHz A, B, and C blocks across

the CONUS GIA, and AT&T and Verizon do not hold all 800 MHz Cellular spectrum in the

CONUS GIA. But, as described above, the licenses of AST Space Mobile’s terrestrial partners

cover a significant portion of CONUS. For example, AT&T and Verizon together hold 1,431 of

the 1,636 active 800 MHz Cellular licenses in the Universal Licensing System (“ULS”) for the

CONUS GIA, amounting to the “the functional equivalent of the entire area of a GIA” as

otherwise contemplated by the SCS Order. 58 Additionally, Verizon has announced transactions

to acquire 160, 800 MHz Cellular licenses (138 from UScellular and 22 from ATN

International), and if approved, Verizon and AT&T together would hold 1,591 the 1,636 active

56
SCS R&O at para. 22.
57
Id. at para. 56.
58
See id. at para. 96 & n.175.

17
800 MHz Cellular licenses or more than 97 percent of the 800 MHz Cellular licenses in CONUS.

Moreover, the Commission has identified only five (5) spectrum bands to support SCS service—

failure to secure a waiver for either the Lower 700 MHz or 800 MHz Cellular bands would

severely restrict U.S. development of a thriving, competitive SCS ecosystem. 59

The Commission also clearly contemplated that advanced technology would be

forthcoming, and deliberately took steps to facilitate waivers of the conservative approach (i.e.,

geographic co-channel separation intended to minimize the risk of harmful interference) it

adopted under its initial SCS rules. As explained in the next section, AST SpaceMobile has a

comprehensive and readily implementable approach to protect incumbents from harmful

interference that conforms to the terrestrial service rules in the 700 MHz and 800 MHz bands.

4. AST SpaceMobile’s Ground-Breaking Technology Will Protect

Incumbent Operators

The Commission established the GIA requirement for the specific purpose of

“minimiz[ing] the possibility for interference between geographically adjacent markets[.]” 60

AST SpaceMobile’s satellite technology is designed to protect co-channel and adjacent channel

licensed operators. AST SpaceMobile’s ability to shape and contour beams enables

comprehensive protection of co-channel terrestrial incumbent spectrum operators. AST

SpaceMobile’s satellites are designed to have a large surface area of phased-array antennas,

which work together to electronically form, steer, and contour coverage beams to align with the

geographic footprints of its cellular partners. AST SpaceMobile’s satellites accomplish this feat

because of its advanced technology, which is able to mitigate potential harms anticipated by the

59
Id. at para. 28.
60
Id. at para. 54.

18
Commission when the SCS rules were adopted without reliance on the conservative guardrails

(i.e., nationwide co-channel spectrum lease rights) established.

More specifically, the active, direct-radiating phased array antennas developed by AST

SpaceMobile employ over nine thousand actively controlled radiating elements. Given this

precise level of control, AST SpaceMobile satellites can adjust service link beamwidth and beam

sidelobes as well as the beam transmit power to mitigate signals that might otherwise propagate

to non-partner licensee service areas. This beamforming technology, complemented by dynamic

adjustments based on a service link’s elevation angle and cell power management, and

selectively vacating cells in close proximity to a neighboring non-partner co-channel licensee,

allows AST SpaceMobile to provide a viable 5G-equivalent service within CONUS from a LEO

orbit while allowing conventional terrestrial cellular service to continue unimpeded in

neighboring non-partner co-channel areas.

The implementation of dynamic beam-forming and complementary interference

mitigations will enable AST SpaceMobile’s constellation to meet applicable field strength limits,

without causing harmful interference to non-partner licensee service areas, or neighboring

countries, Mexico and Canada. 61 In fact, AST SpaceMobile’s modeling demonstrates that in a

real-world implementation, AST SpaceMobile’s field strength will fall several dB below the

FCC and ISED limits and will make AST SpaceMobile a more polite and quiet neighbor vis-à-

vis a conventional terrestrial network. 62

Based on AST SpaceMobile’s ability to comprehensively protect neighboring, non-

partner co-channel licensees in GIA 1, AST SpaceMobile’s waiver request should be granted as

61
See SCS 700/800 MHz Interference Analysis.
62
See, e.g., id. at p. 10, (modeling an AST SpaceMobile service link deployment over Texas, which required de
minimis muting of cells and adjustments to power, even when evaluating unfavorable look angles).

19
the potential for harmful interference into other GIA 1 operations is extremely remote in a real-

world setting, and AST SpaceMobile can quickly adjust or mute transmissions in the unlikely

event such interference occurs.

For a technical analysis of how AST SpaceMobile will protect incumbents, see Annex B

– SCS 700/800 MHz Interference Analysis. Because AST has demonstrated that its operations

will not cause harmful interference to co-channel and adjacent channel licensees for the 800

MHz Cellular and Lower 700 MHz bands, the purpose of the GIA requirement will be fulfilled,

and the waiver request should be granted with respect to both bands.

5. Waiver of the GIA Entry Requirement Is Consistent with FCC

Precedent

Finally, grant of the instant waiver request is consistent with Commission precedent. The

Commission has waived its rules where the use allowed by the waiver will not cause harmful

interference to incumbent users.

In its Galileo Order, for example, the Commission granted waiver of certain of its

licensing rules to allow earth stations in the United States to receive specified transmission from

the European Union-operated Galileo global navigation satellite system. 63 After careful analysis

of the potential impacts on non-Federal transmitters from each of the three proposed Galileo

signals, the Commission concluded that two of the signals presented “no electromagnetic

compatibility issues” 64 and granted the requested waiver with respect to those signals.

More recently, the Commission considered a waiver request filed by the manufacturer of

a low-power indoor access point device seeking to enclose the device with a weatherized

63
Waiver of Part 25 Licensing Requirements for Receive-Only Earth Stations Operating with the Galileo
Radionavigation-Satellite Service, IB Docket No. 17-16, Order, , 33 FCC Rcd 11322 (2018) (“Galileo Order”).
64
Id. at paras. 31, 36.

20
enclosure prohibited by the Commission’s rules. 65 The Commission explained that the intent of

its rule prohibiting such enclosures was “to ensure that [indoor] access points cannot be used

outdoors where the lack of a requirement to use an [automated frequency coordination system]

would increase the potential of causing harmful interference to incumbent spectrum users.” 66

The device manufacturer argued that waiver was necessary to prevent damage to the equipment

and to allow consumers to access the full 1200 MHz of bandwidth available in the 6 GHz band. 67

The Commission granted the waiver, finding that doing so “will not undermine the purpose of

this rule as the [low-power access point device] will only be installed indoors and, therefore, will

not result in an increased potential for causing harmful interference to incumbent users of the

band.” 68

Grant of the GIA Entry Requirement waiver would result in more efficient use of finite

spectrum resources and extend connectivity to underserved Americans without an increased

potential for causing harmful interference to incumbent operators in the 700 or 800 MHz bands.

Consistent with precedent, the Commission should grant the instant waiver request.

IV. GRANT OF THE APPLICATION WILL SERVE THE PUBLIC INTEREST BY

FACILITATING EMERGENCY COMMUNICATIONS, PROMOTING U.S.
LEADERSHIP IN COMMUNICATIONS, AND FOSTERING INNOVATIVE AND
EFFICIENT USE OF SPECTRUM

The public interest will be served by prompt grant of this Application. As the

Commission has acknowledged, “SCS is a crucial component of the Commission’s vision for a

65
Extreme Networks Order.
66
Id. at para. 15.
67
Id. at para. 7 (absent waiver, an alternative device would need to be deployed which, under the Commission’s
rules, would be able to access only 850 MHz of spectrum in the 6 GHz band).
68
Id. at para. 15; see also New Cingular Wireless PCS, LLC, AT&T Mobility Spectrum LLC, and New Cingular
Wireless Services, Inc., Request for Waiver, Call Sign KNLB301, et al., Order, DA 24-1176, para. 10 (rel. Nov. 25,
2024) (granting waiver where doing so “will make productive use of spectrum that has remained underutilized for
over 25 years and essentially eliminates the risk of harmful interference to neighboring operations.”).

21
‘single network future’ in which satellite and terrestrial networks work seamlessly together to

provide coverage that neither network can achieve on its own.” 69 Hybrid satellite-terrestrial

networks are able to connect everyone, everywhere by providing coverage that neither could

achieve alone. When fully deployed, AST SpaceMobile’s planned SCS services will expand the

reach of critical communications services, including during emergencies and natural disasters,

and help bridge the digital divide by facilitating connectivity for more people in more places by

collectively enabling SCS coverage over a significant percentage of the geographic area and

population of CONUS and Hawaii. AST SpaceMobile’s SCS services will also advance the

position of the United States as a global leader in communications and promote the innovative

and efficient use of our nation’s spectrum resources in ways that foster creative collaborations

among users. 70

Because satellite-to-mobile phone connectivity relies primarily on a connection from

space, the service is highly resilient and less likely than terrestrial services to be damaged in

extreme weather or other emergencies. Chairman Carr, after visiting parts of North Carolina

affected by Hurricane Helene, underscored the importance of “robust, resilient, and affordable

connectivity for Americans across the country.” 71 AST SpaceMobile’s SCS services will provide

reliable, real-time communication for emergency responders to coordinate efforts, assess

damage, and deliver aid effectively, even where terrestrial infrastructure is compromised or

unavailable altogether.

69
SCS R&O at para. 1.
70
SCS R&O at para. 2.
71
Brendan Carr, The First Agenda for the New Commission—Spectrum, Public Safety, and Consumer Protection,
FCC BLOG (Feb. 5, 2025), https://www.fcc.gov/news-events/blog/2025/02/05/first-agenda-new-commission-
spectrum-public-safety-and-consumer.

22
 In addition, SCS services also advance important U.S. spectrum-based goals, including

global leadership in the wireless economy and space. 72 As the Commission recognized when

establishing its regulatory framework for the service, removing domestic impediments to SCS

“enable[s] innovations and investments in efficient and effective use of the spectrum, and

foster[s] U.S. leadership in spectrum-based services.” 73 Satellite communications play an

important role in advancing domestic communications policy and achieving U.S. broadband

goals, including positioning the United States to lead in the New Space Age.

Not only will AST SpaceMobile’s first-of-its kind satellite-to-mobile D2D services

advance these goals, but it will also serve the public interest by helping to ensure that spectrum is

used collaboratively and efficiently. AST SpaceMobile’s use of the 700 MHz and 800 MHz

bands for SCS would be consistent with the Commission’s stated goal of enabling more intensive

spectrum use by allocating increasingly scarce spectrum resources in the most efficient and

effective manner possible. 74

Granting this Application will further the Commission’s public interest goals of

expanding the availability of emergency communications and increasing U.S. leadership in the

provision of wireless services.

72
See Office of Chairman Brendan Carr, Chairman Carr Highlights Wins Delivered During First 100 Days, FCC
(April 29, 2025), https://docs.fcc.gov/public/attachments/DOC-411127A1.pdf; Office of Chairman Brendan Carr,
FCC Chairman Carr Announces Early Wins at Launch of Satellite Week, FCC (March 10, 2025),
https://docs.fcc.gov/public/attachments/DOC-410075A1.pdf (“From expanding connectivity, to strengthening
national security, our space industry is delivering real results for the country. For my part, I want America’s satellite
operators and space launch teams to know that the FCC will prioritize your work and partner with you to find
solutions. To expand U.S. leadership in space, I will focus the FCC’s work on speed, simplification, and ensuring
you have the spectrum resources necessary to fuel this sector’s growth.”).
73
SCS R&O at para. 24.
74
In re Single Network Future: Supplemental Coverage from Space, Space Innovation, GN Docket No. 23-65, IB
Docket No. 22-271, Notice of Proposed Rulemaking, 38 FCC Rcd 2790, 2802, at para. 25 (2023).

23
V. ELIGIBILITY, OPERATIONAL, ITU, AND OWNERSHIP REQUIREMENTS

AST SpaceMobile agrees to comply with the Commission’s milestone rules for space

station deployment 75 and confirms that it currently maintains in good standing the required

performance surety bond. 76 Moreover, AST SpaceMobile accepts responsibility to pay any ITU

cost recovery fees associated with this Application. Invoices for such fees may be sent to the

contact noted in the FCC Form 312. 77 Finally, included as Exhibit A is AST SpaceMobile’s

updated ownership information.

VI. CONCLUSION

For the reasons articulated herein, AST SpaceMobile submits that the public interest

would be served by grant of the Application.

Respectfully Submitted,

/s/
Jennifer A. Manner Timothy L. Bransford
Senior Vice President, Regulatory Affairs Denise S. Wood
and International Strategy Kathryne C. Dickerson
Phuong N. Pham Greenberg Traurig, LLP
Vice President, Regulatory Affairs 2101 L Street N.W., Suite 1000
AST SpaceMobile, Inc. Washington, D.C. 20037
(202) 331-3100
(202) 331-3101 (Fax)
timothy.bransford@gtlaw.com
Counsel to AST & Science, LLC

75
47 C.F.R. § 25.164.
76
Id. at § 25.165.
77
Id. at § 25.111.

24