July 1, 2025
By Electronic Filing
Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, N.E.
Washington, DC 20554
Re: Application for Experimental Authority to Launch and Test FM1 Satellite
ELS File No. 0284-EX-CN-2025
Dear Ms. Dortch:
AST & Science, LLC (“AST SpaceMobile”) hereby responds to Space Exploration
Technologies Corp.’s (“SpaceX”) recent filing regarding orbital debris assessment report (“ODAR”)
information submitted with the above-referenced application (“Application”) for experimental
authority to launch and test the FM1 satellite. 1 SpaceX’s latest objections are a rehash of baseless
ODAR-related claims that have been fully refuted, 2 and further demonstrate a continued pattern of
anticompetitive behavior aimed at impeding AST SpaceMobile’s progress toward deploying its
groundbreaking space-based cellular broadband network. Accordingly, the Commission should
dismiss such claims immediately for lack of merit, and grant the Application by July 11 to allow safe
shipment of FM1 by July 12 to the launch site for its upcoming August launch.
ODAR Analysis Fully Consistent with FCC Requirements. Contrary to SpaceX’s baseless claim that
AST SpaceMobile “gamed the system” by using a cross-section modeling approach, AST
SpaceMobile’s ODAR analysis followed the exact methodology requested by Commission staff. As
clarified previously, we provided large object collision risk analyses for the mission phase using a
fixed “side-on” configuration (with station keeping) and separately provided a large object collision
risk analysis for the post-mission phase using a tumbling configuration for the passive decay period.
This approach was not a strategic manipulation but rather utilized at the request of Commission staff.
As such, SpaceX’s objection is demonstrably false and ignores the explicit instructions of Commission
staff.
1
See Letter from Jameson Dempsey, Director of Satellite Policy, Space Exploration Technologies
Corp., Marlene H. Dortch, Secretary, Federal Communications Commission (June 27, 2025).
2
See Letter from Jennifer A. Manner, Senior Vice President, Regulatory Affairs and International
Strategy, AST & Science, LLC, to Marlene H. Dortch, Secretary, Federal Communications
Commission (June 13, 2025) (“AST June 13 Letter”); Letter from Phuong Pham, Vice President,
Regulatory Affairs, AST & Science, LLC, to Marlene H. Dortch, Secretary, Federal Communications
Commission (May 13, 2025).
1
Collision Risk Calculations Based Upon Permissible Estimates. Contrary to SpaceX’s unfounded
claim regarding an underestimate of space objects in nearby orbits, AST SpaceMobile estimated
approximately 700 active satellites that cross FM1's orbit. 3 SpaceX's estimate of 539 payloads,
including unknown objects, debris, and rocket bodies, is misleading and irrelevant to AST
SpaceMobile’s stated commitment to coordinate collision avoidance with other satellite operators.
Coordination is not required to avoid inert debris. Furthermore, to be conservative, we added a margin
to perigee and apogee when counting, which leads to overcounting, not undercounting.
Satellite Reflection Mitigation. As previously noted, AST SpaceMobile continues to work with the
optical astronomy community, including the National Science Foundation, 4 to mitigate both the source
of satellite reflection, and the impact of satellite reflection on, optical astronomy. To this end, AST
SpaceMobile looks forward to continuing its coordination with the optical astronomy community.
Conclusion. SpaceX’s objections appear to be driven by anti-competitive motives. Its attempt to
impose requirements tailored to its system on AST SpaceMobile’s network, despite their fundamental
technological differences, is troubling. Such an approach is inappropriate and hinders innovation and,
as such, must be rejected as baseless.
AST SpaceMobile is committed to complying with applicable FCC regulations and industry best
practices to ensure a safe and sustainable space resource. We are confident that our application and
subsequent filings demonstrate our commitment to safe and sustainable operations. We respectfully
request that the Commission dismiss SpaceX’s objections and request to impose unnecessary
constraints on AST SpaceMobile’s operations and urge the Commission to approve the Application
by July 11 to allow safe shipment of FM1 for its scheduled August launch on time. Failure to do so
will place our ability to launch in August at significant risk.
Sincerely,
/s/ Jennifer A. Manner
Jennifer A. Manner
Senior Vice President, Regulatory Affairs and International Strategy
cc: Jameson Dempsey (SpaceX)
3
See AST June 13 Letter at 4, n.15.
4
See Letter from Timothy Bransford, Counsel for AST SpaceMobile, to Marlene H. Dortch, Secretary,
Federal Communications Commission (May 9, 2025); see also National Science Foundation, Press
Release, NSF and AST SpaceMobile Establish Satellite Coordination Agreement (May 6, 2025),
[Link]
