Globalstar Ex Parte

September 15, 2022
Via Electronic Filing
Marlene H. Dortch
Federal Communications Commission
45 L Street, NE
Washington, D.C. 20554
Re: Ex Parte Notice: Application of Space Exploration Holdings, LLC, IBFS File
No. SAT-MOD-20220906-00100
Dear Ms. Dortch:
On September 6, 2022, Space Exploration Technologies Corp. (“SpaceX”) applied for

authority to use its first-generation NGSO constellation to provide mobile satellite service
(“MSS”) in the United States over Globalstar, Inc.’s (“Globalstar’s”) licensed Big LEO MSS
spectrum at 1610-1617.775 MHz/2483.5-2500 MHz.1 The Commission should reject this request,
which lacks sufficient technical justification, contradicts settled Commission precedent, and
jeopardizes important public interest-enhancing services including emergency services provided
by Globalstar and its partners for more than two decades.2
Originally licensed in the Big LEO band in 1995 and operating continuously since then,
Globalstar is utilizing each of our licensed MSS spectrum channels at 1610-1617.775
MHz/2483.5-2500 MHz for a broad range of services including critical communications.
Globalstar has extended voice, messaging and emergency services to areas not within economic
reach for terrestrial networks and supported thousands of life-saving rescues in the United States
and around the world. With last week’s partner announcement and new service launch, hundreds
of millions of people globally, starting with the United States as the source for the innovation, will
have consumer devices that depend on Globalstar’s system for critical communications.
Globalstar’s licensed MSS spectrum is in short order likely to be one of the most intensively
deployed bands of MSS spectrum in existence. It is unexpected and highly irregular that SpaceX
would make such a request to access Globalstar’s licensed spectrum, which is deployed in good
1
Application of Space Exploration Holdings, LLC for Modification to Deploy a 1.6/2.4 GHz
Mobile-Satellite System, IBFS File No. SAT-MOD-20220906-00100 (Sept. 6, 2022) (“SpaceX
Application”).
2
See, e.g., 47 C.F.R. § 25.112.
faith and at such scale for critical services. Other MSS spectrum which is not intensively used
could be available and suitable for SpaceX’s purpose should it pursue a commercial or other
arrangement with another partner. SpaceX has offered no data and no assessment, and has not
demonstrated that the addition of SpaceX’s proposed operations in Globalstar’s licensed spectrum
band could happen without creating a substantial and untenable risk to Globalstar’s MSS network
and customers. For these reasons, the Commission should expeditiously reject SpaceX’s request.
Globalstar has demonstrated itself to be a strong steward of licensed spectrum, having

originated and continuously innovated hand-held terminals capable of emergency
communications. The Commission established a strong precedent to ensure Globalstar the
regulatory certainty necessary to make the billion-dollar investments required to achieve these
results. In the 2007 Big LEO Order, the Commission stated that its purpose was to achieve “long-
term certainty and stability in the Big LEO market.”3 SpaceX now requests that the Commission
fundamentally undermine that investment certainty and Globalstar’s substantial efforts to
introduce innovative new services such as the transformational direct-to-handset capability
announced last week to an ever-growing customer base.
SpaceX also states that it “has not yet submitted system information for ITU publication”
and that it will submit such information “at the appropriate time to the Commission for filing
through the U.S.”4 Filing for a new system at the ITU for the 1610-1617.775 MHz/2483.5-2500
MHz band, however, would not give SpaceX’s system an equivalent level of priority to antecedent
systems. And, of those previously-filed systems, Globalstar is the only one currently in commercial
operation and with two decades of continuous experience. Given Globalstar’s priority position at
1610-1617.775 MHz/2483.5-2500 MHz, existing critical services depending on the spectrum, and
very established regulatory precedent to protect such incumbent services, any other operator
seeking to use this spectrum would need to successfully complete coordination with both
Globalstar’s U.S.-filed HIBLEO-4 system and French-filed HIBLEO-X system (including current
and future satellites for these systems). Based on the scant data provided to date, SpaceX has not
demonstrated that a successful coordination between Globalstar and SpaceX is possible or that
harmful interference would not be expected from SpaceX’s operations to Globalstar’s MSS
network. In particular, SpaceX has not provided any actual interference analysis to substantiate its
claims about “modern communication technologies, sophisticated phased-arrays, and advanced
beam scheduling protocols inherent in its 1.6/2.4 GHz MSS system” that will prevent harmful
3
Spectrum and Service Rules for Ancillary Terrestrial Components in the 1.6/2.4 GHz Big Leo
Bands/Review of the Spectrum Sharing Plan Among Non-Geostationary Satellite Orbit Mobile Satellite
Service Systems in the 1.6/2.4 GHz Bands, Second Order on Reconsideration, Second Report and Order,
and Notice of Proposed Rulemaking, 22 FCC Rcd 19733, ¶ 17 (2007) (“2007 Big LEO Order”).
4
SpaceX Application, Attachment A at 7.
interference with Globalstar’s systems. Vague statements provide no basis for Commission action,5
especially when harmful interference could upend the safety-of-life services that Globalstar
provides to consumers and inflict irreparable harm on Globalstar’s MSS business.6
* * *
When the Commission established the Big LEO band plan in the 2007 Big LEO Order, it
stated that its spectrum rebalancing in that order was designed to achieve long-term certainty and
stability in the Big LEO market.7 Globalstar relied upon the Commission’s conclusions in that
order to: (1) invest over $1 billion in our second-generation MSS constellation; (2) partner with
others to revolutionize MSS satellite direct to device communications, (3) contract for new satellites
that are substantially in development and will ultimately cost over $500 million to manufacture and
launch to replenish our HIBLEO-4 system; and (4) complete a major upgrade and expansion of our
global ground infrastructure including the addition of ten new ground stations in nine countries. In
the event that licensed spectrum deployed at scale for major customers is repurposed in a way that
threatens existing and future roadmap applications, this action will greatly impact the industry’s
confidence in investing in future satellite services.
Globalstar is eager to compete with MSS systems operating on unused or otherwise

available spectrum, but the Commission should summarily reject unsubstantiated requests that
would undercut regulatory certainty and stability and threaten harmful interference to Globalstar’s
5
While SpaceX states in its application that it has provided a completed Schedule S with its filing
(SpaceX Application at 1; Attachment A at 3, 6; Waiver Requests at 5), there is currently no Schedule S
associated with its application in the Commission’s IBFS database. See https://licensing.fcc.gov/cgi-
bin/ws.exe/prod/ib/forms/reports/swr031b.hts?q_set=V_SITE_ANTENNA_FREQ.file_numberC/File+Nu
mber/%3D/SATMOD2022090600100&prepare=&column=V_SITE_ANTENNA_FREQ.file_numberC/F
ile+Number (last visited Sep. 15, 2022).
6
SpaceX’s approach, disregarding interference concerns and failing to apply any interference
analysis, is very inconsistent with SpaceX’s simultaneous insistence on data-driven interference analysis
with respect to the bands on which it depends, such as 12 GHz. See, e.g., Reply Comments of Space
Exploration Holdings, LLC, WT Docket No. 20-443, GN Docket No. 17-183, at 4-5 (“RS Access’s
technical study is fatally flawed, transparently biased, and still is unable to avoid the conclusion that the
MVDDS Licensees’ sought-after windfall will harm incumbents”) (July 7, 2021); Letter from David
Goldman, Director, Satellite Policy, Space Exploration Technologies Corp., to Marlene H. Dortch,
Secretary, FCC, at 3-4 (“The single submission that the MVDDS licensees presented to support their more
recent claims has been exposed by many commenters to be so flawed as to be rendered completely
unreliable…Even putting aside the many other flaws of this report discussed in the record, this egregious
one alone calls into question the reliability of the submission’s conclusions.”) (Nov. 29, 2021).
7
2007 Big LEO Order ¶ 17.
systems, interfering with services offered for the greater good on the Globalstar network, and
materially impairing capacity and investments made in good faith to support and extend its
duly-licensed MSS operations.
Respectfully submitted,
/s/ L. Barbee Ponder IV

L. Barbee Ponder IV
General Counsel & Vice President, Regulatory
Affairs
Globalstar, Inc.
1351 Holiday Square Blvd.
Covington, LA 70433
CERTIFICATE OF SERVICE
I, Judith Loo-Day, hereby certify that on this 15th day of September 2022, a copy of the
foregoing letter is being sent via first class, U.S. Mail, postage paid to the following:
David Goldman
Brett Tarnutzer
Space Exploration Holdings, LLC
1155 F Street, NW
Suite 475
Washington, DC 20004
/s/ Judith Loo-Day

Judith Loo-Day

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September 15, 2022

Via Electronic Filing

Dear Ms. Dortch:

On September 6, 2022, Space Exploration Technologies Corp. (“SpaceX”) applied for

Globalstar has demonstrated itself to be a strong steward of licensed spectrum, having

Globalstar is eager to compete with MSS systems operating on unused or otherwise

/s/ L. Barbee Ponder IV

/s/ Judith Loo-Day

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