Elon Musk’s Latest Unofficial Task Force
In a move that feels equal parts shocking as it is on-brand, SpaceX just flashed its orbital watchdog badge to the FCC in what is being characterized as a “transparent attempt to hijack competition, hinder innovation, and impair national security.”
Channeling a DOGE-inspired lawfare vibe, SpaceX is now weaponizing Starlink to form some sort of on-orbit Department of Spectrum Enforcement. DOSE (our acronym, not theirs) is collecting Power Spectral Density (PSD) data over the 2 GHz band across the Northeastern U.S., Western U.S., and Alaska – territory where EchoStar (parent of Dish Networks) holds licenses for both Mobile Satellite Service (MSS) and terrestrial 5G use under the FCC’s (AWS-4) designation.
Simply put: SpaceX just deployed a spectrum spy op to make EchoStar look like a squatter. The goal seems less enforcement than eviction. Basically, if you’re not using your spectrum, Elon will. And the way things are going, the FCC might even DOSE you into forfeiting it.
SpaceX is DOSEing up with Data
This long-simmering regulatory clash between SpaceX and EchoStar reached a boiling point on April 14. Through PSD data collected by Starlink satellites, SpaceX illustrated for the FCC its claim that EchoStar uses just 5% of its licensed AWS-4 spectrum – a figure that, if accurate, contradicts years of buildout milestones.
Image Credit: SpaceX FCC Filing (WT Docket No. 22-212; RM-11976; ICFS File No. SES-RWL-20241213-02647)
Starlink’s satellites¹ essentially acted as passive RF monitors, scanning the 2 GHz band over parts of the U.S., specifically, the Northeast, West, and Alaska. Possibly not by accident, the areas surveyed may include some of the most sparsely populated zones within EchoStar’s AWS-4 footprint. Think Jersey City vs. Jasper. Data from this surveillance mission showed that while adjacent frequencies lit up with signal activity, EchoStar’s AWS-4 spectrum remained quiet by comparison.
While we would expect spectrum watchdogging from RF signal mapping players like HawkEye 360, Starlink acting as a space-based spectrum spy was not on our bingo card. Worth noting that SpaceX doesn’t appear to be deploying any new payloads. It’s likely reprogramming and tasking Starlink’s advanced phased array beamforming and digital signal processing technologies to conduct the passive spectrum audits.
EchoStar’s Counterpunch
EchoStar clapped back at SpaceX for orchestrating a regulatory ambush and attempting to rewrite FCC precedent through media spectacle. In an April 15 filing and a statement to Octus, EchoStar accuses SpaceX of its “familiar pattern” of “distorting the truth while missing the point” and dismisses SpaceX’s PSD scans as irrelevant. EchoStar goes on to explain that AWS-4 buildout obligations are population-based, not geographic: “Perhaps SpaceX is confused because it has never publicly filed a detailed deployment report for the 15,000 MHz of spectrum it received free of charge from the FCC.”
Contrast, as they did, with EchoStar’s own track record of investing more than $30B in wireless spectrum licenses and $7.3B+ in capex to build out a nationwide 5G network. The company also pointed to the FCC’s September 2023 determination that Dish Networks met its 70% population coverage requirement and cited third-party certification of EchoStar’s March 2024 nationwide drive tests. With 23,000+ 5G sites online, EchoStar now claims to be the largest Open RAN network in the country.
The rebuttal painted SpaceX not as a champion of efficiency, but as a spectrum opportunist trying to kneecap EchoStar’s emerging DTD strategy, just as its first Lyra satellite (launched in January 2025 aboard SpaceX’s Transporter-12 mission) begins operations under an FCC experimental authorization.
EchoStar also dismissed SpaceX's criticism of temporary spectrum leasing as irrelevant, clarifying that the leases were approved by the FCC as part of a 5G milestone extension agreement to foster interim spectrum use by smaller operators and Tribal nations during EchoStar’s network buildout.
SpaceX Reloads
On April 18, SpaceX submitted a follow-up letter to the FCC, reinforcing its earlier claims and openly ridiculing EchoStar for offering no meaningful rebuttal to the spectral data presented. Instead of addressing the core issue of underutilized spectrum, EchoStar “attacks the messenger,” SpaceX said, and fails to explain “the measured wasteland in the AWS-4 band.”
More provocatively, SpaceX asserted that the FCC has never validated EchoStar’s drive test claims, despite EchoStar suggesting otherwise. SpaceX is now urging the Commission to revisit EchoStar’s buildout filings to assess whether the milestones were meaningfully met or just rubber-stamped.
SpaceX also mocked EchoStar’s effort to anchor its AWS-4 spectrum rights to the launch of a single, foreign-licensed NGSO satellite (Lyra-1), calling the legal logic “bizarre.” If EchoStar admits that NGSO operations are viable in the band, SpaceX argues, “the Commission should allow more NGSO operations in the band.”
EchoStar's Latest Salvo: We Built This, Back Off
On April 23, EchoStar returned fire in yet another FCC Filing, accusing SpaceX of inventing an unrecognized standard for compliance to upend decades of licensing framework. The filing warns the Commission that allowing SpaceX’s interpretation to stand would violate FCC precedent, undermine EchoStar’s dual-use MSS + 5G architecture, and trigger harmful interference scenarios the AWS-4 Order aimed to avoid. EchoStar emphasized the FCC's explicit certification of its AWS-4 deployment, reiterated its leadership in 3GPP’s non-terrestrial network (NTN) standardization work, and boasted about an audit that ranked Boost Mobile — powered by its network — as the most reliable in New York City. Also, National Security and China.
Globalstar’s Big LEO Lockdown
Meanwhile, Globalstar has been fortifying its own defenses to protect its Big LEO spectrum from the de facto leader of DOSE. In an April 10 meeting with the FCC’s Space Bureau and Commissioner Carr’s staff (note: not Carr), it pressed for swift approval of its C-3 constellation without first detonating a rulemaking that would blow open the back door for SpaceX to share its 1.6/2.4 GHz band. That’s not paranoia. SpaceX already filed a petition in February 2024 to dismantle Big LEO’s exclusive use. That proposed rulemaking [RM-11975] is still on the docket.
In an April 15 ex parte filing, Globalstar framed the C-3 System as the next evolutionary leap for DTD to bolster its existing SPOT devices, IoT offerings, and iPhone SOS integration. Globalstar warned that even initiating a new Big LEO rulemaking would undermine investment certainty, derail commercial momentum, and jeopardize a framework that “supports the provision of MSS to more people globally than any other satellite band.”
If (when?) that petition advances, Globalstar and fellow incumbents like Ligado and Iridium could be the next to stare down a DOSE audit.
SpaceX’s Playbook: Just Rewrite the Rules
SpaceX isn’t really accusing EchoStar of breaking the rules. It’s saying the rules themselves are broken if legacy benchmarks and compliance metrics amount to little more than performative box-checking.
Enter DOSE: a data-driven pretext for broader reform. Sound familiar? DOSE is shaping up to be just what the FCC needs to justify revising the 2 GHz and/or Big LEO licensing framework to enable shared spectrum use prioritized for next-gen NGSO (read: Starlink) systems. Should the Commission agree, it will erode legacy operators’ grip on certain bands and fundamentally shift the balance of spectrum power.
This regulatory recalibration is not just about the players, though. It’s about the game. And how SpaceX is nudging the FCC to change the rules in a time when satellites don’t just provide connectivity, they apparently police it. If compliance shifts from paperwork to prove it, then we are ushering in the beginning of a regulatory Hunger Games.
And in this arena? The odds feel ever in SpaceX’s favor.
1. The PSD data in SpaceX’s April 14 filing was collected in Q4 2024, prior to the launch of its v2 Mini Optimized satellites in March 2025, suggesting the use of its Direct to Cell satellites.
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