Comments to FCC Regarding Assignment and Transfer of Control of Licenses and Authorizations Held by Globalstar to Amazon
Introduction and Summary
The Information Technology and Innovation Foundation (ITIF) appreciates the opportunity to comment on the assignment and transfer of control of licenses and authorizations held by Globalstar, Inc. to Amazon.com, Inc.[1] ITIF supports approval of the proposed transaction because it will promote more productive use of Globalstar’s internationally harmonized Mobile-Satellite Service (MSS) spectrum, strengthen competition in the emerging direct-to-device (D2D) market, and expand connectivity to areas that currently lack reliable Internet access.[2]
THE TRANSACTION WILL PROMOTE MORE PRODUCTIVE USE OF GLOBALSTAR'S MSS SPECTRUM
The goal of spectrum policy should be to maximize the productivity of spectrum.[3] Amazon’s demonstrated satellite production capabilities indicate that it can manufacture satellites at a substantially greater scale than Globalstar.[4] Greater production capabilities are important for satellite Internet because network capacity and resiliency generally grow in parallel with the number of operational satellites, leading to better service for D2D customers.[5]
Additionally, Amazon’s planned satellites incorporate advanced beamforming and spot-beam architecture.[6] The capabilities of each satellite in a constellation enhance overall network performance, so a constellation of newer satellites will provide better service than one with legacy satellite technology. Taken together, a larger constellation of more advanced satellites will enable Amazon’s planned D2D constellation to use the 1.6/2.4 GHz spectrum more productively than Globalstar can, which makes this transaction a success for spectrum productivity.
THE TRANSACTION WILL STRENGTHEN COMPETITION IN THE D2D SATELLITE MARKET
Amazon is well-capitalized, and already has multiple satellite systems, ground stations, spectrum licenses, and a robust satellite manufacturing and processing capacity. These resources and institutional knowledge put Amazon in a good position to enter the emerging MSS market as a strong competitor.
However, despite Amazon's substantial resources and technical capabilities, it has no commercially viable path to offering D2D service without the transaction. The 1.6/2.4 GHz MSS allocation is one of the few globally harmonized MSS bands.[7] The FCC's 2007 band reconfiguration granted Globalstar exclusive MSS operating rights, and the Commission’s current licensing framework does not provide a practical mechanism for new entrants, such as Amazon, to obtain comparable rights in this band as a standalone applicant.[8] Additionally, creating a comparable globally harmonized allocation through the ITU process would take decades, and Globalstar also holds nearly thirty years of international landing rights and operating authorizations across more than 100 countries.[9] These regulatory approvals and international operating rights cannot readily be replicated, meaning the transaction represents Amazon's most practical path to D2D market entry on a meaningful timeline.
The addition of another well-resourced provider will promote greater competition among satellite operators offering D2D services. Increased facilities-based competition may encourage continued private investment, technological innovation, and improvements in network performance and service quality.[10] Greater competition will also lead to greater affordability and consumer choice as providers compete to attract subscribers.[11]
THE TRANSACTION WILL EXPAND SATELLITE CONNECTIVITY
The proposed transaction will advance the Commission's broader connectivity objectives by supporting expanded satellite communications capabilities in areas that remain difficult to serve through terrestrial infrastructure alone.[12] D2D satellite services have the potential to extend mobile communications coverage to rural communities, maritime and aviation users, disaster-affected areas, and other remote locations where terrestrial deployment is unavailable or economically impractical.[13]
CONCLUSION
The Commission should approve this transaction because it will serve the public interest by increasing spectrum productivity, increasing competition in the emerging D2D marketplace, and extending mobile communications coverage to remote and underserved areas.
Thank you for your consideration.
Endnotes
[1]. Founded in 2006, ITIF is an independent 501(c)(3) nonprofit, nonpartisan research and educational institute—a think tank. Its mission is to formulate, evaluate, and promote policy solutions that accelerate innovation and boost productivity to spur growth, opportunity, and progress. ITIF’s goal is to provide policymakers around the world with high-quality information, analysis, and recommendations they can trust. To that end, ITIF adheres to a high standard of research integrity with an internal code of ethics grounded in analytical rigor, policy pragmatism, and independence from external direction or bias. For more, see: “About ITIF: A Champion for Innovation,” https://itif.org/about; Public Notice, Assignment and Transfer of Control of Licenses and Authorizations Held by Globalstar, Inc. to Amazon.com, Inc, GN Docket No. 26-134, FCC, June 4, 2026, https://docs.fcc.gov/public/attachments/DA-26-550A1.pdf, (Notice).
[2]. See Application for Consent to Assignment and Transfer of Control of Licenses and Authorizations and Public Interest Statement, Amazon.com, Inc. and Globalstar, Inc., ICFS File No. ITC-T/C-20260417-00114, May 26, 2026, (Transaction).
[3]. See, Ronald Coase, “The Federal Communications Commission,” The J. of L. and Econ., Oct. 1959, 27. “It is sometimes implied that the aim of regulation in the radio industry is to minimize interference. But this would be wrong. The aim should be to maximize output.”
[4]. Shaun Waterman, “Amazon Leo Readies 200+ Satellites for Orbit as It Ramps Up Launch Schedule,” Via Satellite, March 23, 2026, https://www.satellitetoday.com/connectivity/2026/03/23/amazon-leo-readies-200-satellites-for-orbit-as-it-ramps-up-launch-schedule/.
[5]. Micheal Bennet and Corinne Kramer, “Large Constellations of Low-Altitude Satellites: A Primer,” Congressional Budget Office, May 2023, https://www.cbo.gov/publication/59175#_idTextAnchor073.
[6]. See Amazon-Globalstar application at page 17-18.
[7]. Report and Order, Amendment of the Commission’s Rules to Establish Rules and Policies Pertaining to a Mobile Satellite Service in the 1610-1625.5/2483.5-2500 MHz Frequency Bands, CC Docket No. 92-166, FCC, 1994, https://www.govinfo.gov/content/pkg/FR-1994-02-28/html/94-4409.htm.
[8]. Second Order on Consideration, Second Report and Order, and Notice of Proposed Rulemaking, Spectrum and Service Rules for Ancillary Terrestrial Components in the 1.6/2.4 GHz Big LEO Bands; Review of the Spectrum Sharing Plan Maong Non-Geostationary Satellite Orbit Mobile Satellite Service Systems in the 1.6/2.4 GHz Bands, IB Docket No. 07-253, FCC, 2007, https://docs.fcc.gov/public/attachments/FCC-07-194A1.pdf; Order, Applications for Modification of Authorization for the SpaceX Gen2 NGSO Satellite System to Add a Mobile-Satellite Service System, ICFS File No.: SAT-MOD-20230206-00022, FCC, March 25, 2024, https://docs.fcc.gov/public/attachments/DA-24-300A1.pdf.
[9]. See Amazon-Globalstar application at page 16.
[10]. Ellis Scherer and Joe Kane, “Broadband Convergence Is Creating More Competition,” ITIF, July 7, 2025, https://itif.org/publications/2025/07/07/broadband-convergence-is-creating-more-competition/.
[11]. Ibid.
[12]. “FCC Clears the Way for American Leadership in Next-Gen, Direct-to-Device Connectivity,” FCC, April 23, 2026, https://docs.fcc.gov/public/attachments/DOC-420983A1.pdf.
[13]. See Amazon-Globalstar application at page 20.
