What is deployed today

Only two satellite operators hold American terrestrial rights

The FCC’s market licence file of 13 September 2026, filtered to active records held by licensee-type entities, shows two satellite operators with American terrestrial rights. AST & Science holds 1,197 records and Space Exploration Holdings holds 175 (Exhibit 1).

Almost none of it is owned. Every one of AST’s 1,197 records is a lease: permission written against spectrum for which another company holds the licence. SpaceX’s position is similar, with 173 leases in the PCS G block and two market licences granted on 26 August 2026. Part 4 covers the difference between the two kinds of record. Every other direct-to-device operator is either an incumbent working on mobile-satellite spectrum of its own or a prospect with no American terrestrial rights.

AST’s 654 markets against SpaceX’s 174 say nothing about either company’s ambition. A lease inherits the geography of the licence beneath it, and the two bands were divided differently when first licensed. The 700 MHz lower blocks were licensed in cellular market areas, which are small, so AST’s footprint comes in 654 pieces. The PCS G block was licensed in economic areas, which are larger, so SpaceX’s comes in 174. The market counts describe the band plans rather than the companies.

Each position was granted on one day and expires on one day

Each date in the file matches an FCC order to the day. AST’s records trace to the Bureau order adopted on 21 April 2026, which also covers the lease notifications filed with AT&T, Verizon and FirstNet. SpaceX’s trace to the order of 26 November 2024 that authorised supplemental coverage from space in the PCS G block. For each position the file and the order agree.

The expiry dates set the two positions apart. All 1,197 of AST’s authorisations expire on 9 May 2028, so its entire American footprint rests on a single date, twenty months after the September 2026 snapshot. Every one of SpaceX’s 173 leases carries 3 March 2026, a date that had already passed at the snapshot, while every other holder in the PCS G block shows 2036. The file alone does not explain the discrepancy; part 4 looks at it more closely (Exhibit 2).

The dates matter because a position granted in a day can be withdrawn in a day. Neither company bought these rights at auction; both hold them at the pleasure of a landlord and a regulator, and in our view the expiry dates deserve more attention than the record counts. Everything AST has launched, and everything a partner or investor has committed to it, rests on the May 2028 date being extended. Nothing on the public record says it will be.

Neither company owns the spectrum its consumer service depends on. Both are tenants, and the tenancy has dates on it.

The file describes what was held on 13 September. What has been contracted since is larger. SpaceX’s EchoStar purchase, 65 MHz between 1.7 and 2.2 GHz, sits in a trust until a closing expected in November 2027, and on 8 October 2026 SpaceX agreed to buy a second position, up to 14 MHz of paired 800 MHz spectrum, from Grain Management (release), subject to the FCC’s consent. Neither is in the file, because neither has closed. The file shows who can transmit today, and today both operators are tenants.

The absences are as telling. Globalstar, Iridium and Skylo appear nowhere in these records because each operates in mobile-satellite spectrum it holds in its own right, which puts an incumbent in a far stronger negotiating position than a newcomer renting a carrier’s. Two of the three have since agreed to be bought, Globalstar by Amazon on 13 April 2026 and Iridium by Rocket Lab on 28 June 2026; part 6 sets out the terms.

Four fleets fly at four different altitudes

The four fleets that bear on this market are not variations on a single design. Each operator has settled on an altitude, an inclination and a fleet size, and together the three choices describe a commercial position rather than an engineering one (Exhibit 3).

Starlink keeps most of its fleet between 400 and 580 km, in four measurable shells. A further 824 of its 10,702 objects were below 400 km at the September epoch, consistent with the 340 to 360 km shells the 2024 order describes. AST flies at much the same height and has made the opposite choice about everything else. The two sampled BlueBirds flew at about 505 and 527 km at 53°, and its order describes altitudes near 515 to 530 km and 680 to 690 km, but the whole constellation is to be 223 to 243 satellites, each far larger than a Starlink. Lynk’s Tower 4 was at about 462 km in a 97.3° sun-synchronous orbit. Globalstar, the incumbent, flies its 28 satellites far above all of them, at 1,414 to 1,830 km and 52° (Exhibit 4).

Only two of the four compete for the same consumer service. Starlink’s many small satellites flown low and AST’s few large ones flown higher are rival ways of closing the same link to a phone, and each commits its operator to a different kind of fleet for years. The other two serve different purposes. A sun-synchronous fleet like Lynk’s passes over everywhere at intervals rather than lingering over one place. A small constellation in high orbit, on spectrum it owns, is the profile of an incumbent.

Inclination reads as an engineering parameter and is a commercial choice first. A 53° shell concentrates capacity over the populated mid-latitudes. A 97° sun-synchronous orbit passes over everywhere and lingers nowhere, which suits messaging and does not suit a service that has to feel like coverage.

Altitude is a trade. A higher satellite sees more of the ground at once and stays over any given point for longer, but has to work much harder to close a link to a phone in someone’s hand; AST’s bet is to build large and launch few. A lower satellite closes the link more easily and has a shorter life, so the operator builds small and launches constantly, which is Starlink’s approach. Part 3 works through the link budget each design has to close, and the non-terrestrial series sets out what each orbit is good for.

None of the three Starlink counts in circulation is the number serving phones

Three different Starlink counts are in circulation, and they measure different things. The FCC’s order of 26 November 2024 authorises supplemental coverage across up to 7,500 Gen2 satellites, which is a ceiling. CelesTrak’s satellite catalogue held 11,123 Starlink payloads on orbit on 17 September 2026, which is a fleet. Its element sets at that epoch held 10,702 Starlink objects, of which 824, or 7.7%, flew below 400 km, where the order places the direct-to-cell shells (Exhibit 5). None of the three is the number serving phones, because the public catalogue cannot distinguish a satellite carrying direct-to-cell hardware from one without. The only source for that figure is SpaceX, whose prospectus of 12 June 2026 puts the fleet at approximately 650 V1 Mobile satellites, serving approximately 7.4 million monthly unique devices across approximately 30 countries.

Two of the gaps between those figures are ordinary. An authorisation and a fleet measure different things, so the 7,500 and the 11,123 need not match, and the catalogue and the element sets differ because an object can be on orbit without a current element set in a given pull. The gap between all of those and the 650 is different in kind: nothing in a public catalogue separates a satellite with direct-to-cell hardware from one without, so no counting from outside can close it. An authorisation is a ceiling, a catalogue count is a fleet, and neither is a service. The 15,000 authorised on 6 October 2026 is the largest ceiling and the furthest from a fleet: none of those satellites has been launched, and the order gives SpaceX until 7 October 2032 to fly half of them.

Press coverage routinely blurs the three counts. Anyone weighing a direct-to-device claim should ask which one is being quoted. The only figure that describes the service comes from the company, and nothing in the catalogue can check it.

Terms used

• Lease. Permission to use spectrum that another company is licensed to hold, for a term that cannot outlast the licence beneath it. In the FCC file a lease has a different form of call sign from a licence.
• Cellular market area (CMA). One of the small geographic units in which the 700 MHz lower blocks were licensed. AST’s 654 markets are mostly of this kind.
• Economic area (EA). A larger licensing unit. The PCS G block SpaceX leases is licensed in economic areas, and 174 of them appear in its records.
• Supplemental coverage from space (SCS). The FCC’s framework, in GN Docket 23-65, under which a satellite operator may transmit on a terrestrial carrier’s spectrum to supplement that carrier’s coverage.
• Element set. The two-line orbital elements CelesTrak publishes for a tracked object, from which mean motion converts to altitude. An object can be on orbit in the catalogue without a current element set in a given pull, which is why the two Starlink counts differ.