Thesis · The unbundling of orbital commodities
Orbital commodities are unbundling. We clear what crosses bilaterally underneath.
Wavestar Research
Last revised
May 2026
Status
Living document
Version
v0.2 — post-EPFD revision
The pattern
Bilateral OTC markets break under volume. A clearing house arrives.
London Produce Clearing House — what is now LCH — was founded in 1888 because bilateral coordination of London commodity contracts had outgrown the institutions clearing them. The clearing house was the response to volume, not the precursor. The volume was already crossing. It just was not netting, novating, or reducing counterparty risk.
LCH SwapClear was launched in 1999 because the bilateral OTC interest-rate swap market had been growing for fifteen years without post-trade infrastructure. The market was unbundled, large, and uncleared. SwapClear arrived at the inflection point — and within a decade was the dominant clearer of OTC rates. The shape repeats: bilateral volume first, clearing infrastructure second, regulatory mandate third.
The orbital commodities market is in the same window today. $28B of bilateral spectrum coordination over eighteen months. A regulatory door that opened five days ago. A vertically-integrated incumbent (Microsoft) that has already exited the adjacent ground-station market. The substrate standardised by SDA's optical comms framework. The pieces that have to be in place before a clearing house works are in place.
A clearing house arrives when bilateral volume gets too large to net by hand. That moment has arrived in orbit — it has just not been named yet.
The four forcing functions
Four things flipped in eighteen months. None had flipped two years ago.
- 01
FCC EPFD modernisation · April 30 2026
The Federal Communications Commission voted to modernise the Equivalent Power Flux Density framework that has governed NGSO/GSO interference for three decades. The replacement regime is explicit: NGSO and GSO operators can bargain for interference protections through voluntary, private agreement. Private spectrum coordination is now the regulatory default. The FCC's own estimate is $2B+ in unlocked economic benefit and a sevenfold increase in space-based broadband capacity — both of which assume someone builds the coordination layer underneath. - 02
$28 billion of bilateral spectrum deal flow
Eighteen months of direct-to-device spectrum transactions — AST/Verizon, SpaceX/T-Mobile, Globalstar/Apple, the reported Amazon/Globalstar talks. The headline transactions are the visible part of a substantially larger long tail of bilateral coordination between operators, telcos, and integrators. None of this volume is cleared. There is no netting, no neutral price discovery, and no standardised contract. This is the empirical answer to the demand question. - 03
Ground-station fragmentation
Microsoft retired Azure Orbital in 2024. EQT acquired Eutelsat's ground-station assets the same year. AWS, KSAT, Leaf Space, Atlas Space, and the long tail are vertically integrating — each pulling operators into a proprietary stack that does not interoperate cleanly with the others. The neutral coordination layer between operators and ground infrastructure is missing, and the largest cloud provider has already chosen not to build it. - 04
SDA optical comms standard · live
The Space Development Agency's optical inter-satellite-link standard is now the compliance reference across military and commercial terminals. Kepler launched its commercial optical relay constellation in January 2026 with explicit SDA compatibility. Cross-constellation ISL capacity is technically fungible for the first time — the precondition for a clearable wholesale market.
The wedge
Spectrum is the loudest signal. Downlink is the simplest unit. Both are the same thesis.
Spectrum is where bilateral commodity volume is loudest today. $28B in eighteen months. The FCC has just endorsed private bargaining as the coordination model. It is the largest, fastest-moving signal in the orbital economy.
Downlink minutes are the simplest unit of bilateral capacity to authenticate, clear, and settle. A downlink minute has a defined ground station, a defined antenna, a defined band, a defined window. It is countable, deliverable, and contestable — the three properties a clearing house requires of its underlying. So downlink is what the v1 cleared market is. It ships first because it ships cleanly.
Both are the same unbundling thesis. The orbital commodities market is becoming a market of standardised contracts traded between heterogeneous counterparties. We are the post-trade infrastructure that becomes inevitable underneath. Spectrum is the loudest signal of demand. Downlink is the simplest unit to clear. The two markets reinforce each other — the regulatory path that licenses one licenses the other; the attestation framework that signs one signs the other.
Spectrum is where the volume is. Downlink is where settlement ships first. The choice is not between them — it is the order in which we open the cleared markets.
The unbundling map
What is unbundling, and from whom.
An unbundling thesis is concrete. It names what is being separated, who is being separated from whom, and what new market structure replaces the integrated arrangement. For the orbital commodities market, the unbundling is happening in five identifiable places — each at a different stage. The wedge follows the maturity of the unbundling, not the size of the market.
What is unbundling, and where
- Spectrum coordination
- From regulators to operators
FCC EPFD modernisation hands NGSO/GSO interference protection to private bargaining. $28B of bilateral volume already crossed in 18 months.
- Downlink capacity
- From hyperscale clouds to neutral GSaaS
Azure Orbital exited 2024. AWS is locked into its own stack. The neutral coordination layer between operators and ground stations is missing.
- ISL capacity
- From constellation-internal to wholesale
SDA's optical standard makes cross-constellation links fungible. Wholesale trade is forming but not yet at scale.
- Hosted payload slots
- From bilateral RFQs to listed marketplaces
SDA HALO institutionalises hosted-payload procurement across nineteen commercial vendors. The directory exists; the marketplace is forming.
- Propellant / ISAM
- Substrate forming, market not yet
GAO July 2025: chicken-and-egg problem persists. NASA cancelled OSAM-1/OSAM-2. Clearable market window is 2027-2028 when standards lock.
Adjacent institutions
LCH is the analog. Why not DTCC.
The first investor question is some version of “why won't DTCC do this?” — and it is the wrong question. DTCC is structurally a securities clearer. Its subsidiaries clear SEC-regulated equities, fixed income, and custody. Its members are broker-dealers and tier-1 banks. Its default fund mechanics assume bank capital.
Wavestar clears commodities and services. CFTC jurisdiction, not SEC. Members are operators, ground stations, and ISAM providers — not banks. The institution Wavestar is modelled on is LCH, a 137-year-old commodity-and-OTC-derivatives clearing house that was created when London produce markets outgrew bilateral coordination, and re-created in 1999 when OTC interest-rate swaps did the same thing.
The full DTCC vs CME vs LCH comparison is a page on its own. The short version: DTCC is the wrong analog because it is the wrong statute, the wrong members, the wrong contracts, and the wrong governance speed. None of that is a knock on DTCC — it is just a different kind of clearing house.
The right pattern-match is the commodity clearer that did not exist until the bilateral market got too big — not the securities clearer that exists today.
Objection handling
Four things people say. Why they are wrong.
- A
"There is not enough bilateral volume yet."
$28 billion of direct-to-device spectrum deal flow has accumulated in eighteen months — uncleared, bilateral, in public reporting. The Ground Station as a Service market is between $0.5B and $1.4B in 2024 and growing 15-19% CAGR. Hosted-payload procurement is institutionalised across nineteen vendors via SDA HALO. The volume question was a 2023 question. It is not a 2026 question. - B
"This is too novel for a standard CCP framework."
This is approximately what was said about interest-rate swaps in 1987, credit derivatives in 2002, and digital assets in 2018. In all three cases the answer was not a novel clearing construct. It was the slow, disciplined application of standard CCP practice to an asset with novel delivery mechanics. We are taking the same path — standard DCO structure, standard member margin, standard default-fund waterfall — with settlement primitives tuned for the physics of orbit. - C
"Why won't DTCC clear this?"
Because DTCC is a securities clearer. We clear commodities and services. Different statute (CFTC, not SEC), different member structure (operators, not banks), different default fund mechanics, and a contract architecture that does not yet exist outside of Wavestar. LCH is the structural analog. The full comparison lives on /about/why-not-dtcc. - D
"Clearing houses are heavily regulated. You will be gated forever."
Regulated infrastructure is the moat, not the obstacle. FinCEN MSB across 50 jurisdictions plus CFTC DCO designation take 30+ months and serious capital — exactly the barrier that protects a market-infrastructure entrant once it banks the approvals. We file on four tracks in parallel (FinCEN MSB, SEC ATS, CFTC DCO, CFTC SEF/DCM) not because we enjoy regulatory work, but because the jurisdictional mapping is the moat we are building.
The second-order market
The clearing fee is the loss leader. The index, the data, and the attestations are the prize.
The primary settlement volumes — spectrum-hours, downlink minutes, ISL capacity, hosted payload, propellant — are a meaningful market on their own. They are also the smallest part of the opportunity. The second-order market that becomes possible once these are cleared, referenceable, and attested is where the trillion-dollar economy lives.
Financing becomes possible against a receivable you can prove. Insurance becomes underwriteable against a loss you can measure. Derivatives become priceable against a reference index you can trust. Each of those categories is, on Earth, larger by an order of magnitude than the primary spot market it sits on top of. We expect the same ratio in orbit.
Internal planning treats the clearing fee as a loss leader for the index, the data, and the attestation layer. Which is, we note, exactly how CME Group has thought about its business for thirty years.
Spot volume — year 5
$8–12B
Clearable notional across the asset-class roadmap.
Second-order potential
$80B+
Financing · insurance · derivatives built on top of the primary market.
Index license revenue
Recurring
Per-operator and per-instrument reference-data licensing.
Attestation volume
Per-settlement
Every settled fact is a paid attestation. Volume scales linearly.
The roadmap
Downlink first. Spectrum second. The rest follow as standards lock.
- 2026In progress
Downlink minutes — the v1 cleared market
The simplest unit of bilateral capacity to authenticate, clear, and settle. Defined ground station, defined antenna, defined band, defined window. High counterparty diversity, tractable settlement complexity. This is what ships first. - 2026-27Planned
Spectrum-hours — the loudest bilateral signal
ITU-coordinated and FCC-licensed spectrum traded as hour-blocks with operator-bound rights. The $28B bilateral signal becomes a cleared market as the EPFD private-bargaining regime matures and the SEC ATS-N filing goes operative. - 2027Planned
ISL capacity — the first optical-native instrument
Optical inter-satellite link hours, cleared as a standardised unit against SDA-compatible terminals. Reference pricing published. First forwards contracts. - 2027-2028Planned
Hosted-payload slots — the marketplace for spacecraft bus capacity
Listed, discoverable, and bookable bus slots. Secondary trading with atomic swap into ORCH. SDA HALO already establishes the procurement pattern. - 2028+Planned
Propellant / ISAM — when the standards lock
Per GAO July 2025, ISAM is in a chicken-and-egg window. CONFERS and ISO/DIS 24330 standardisation is underway. Clearable when grapple-fixture standards lock — expected 2027-2028 per industry tracking.
The close
Why now, why this team, why this institution.
A clearing house is not a clever piece of technology. It is an institution. Institutions are built by people willing to live inside boring regulatory disciplines for years before the payoff shows up. The team here has the structured-finance background to do that without surprise, the multi-jurisdictional payments background to know what operational resilience actually looks like, and the engineering background to build the primitives from the ground up in the right languages.
The window is short. The pattern is clear. The regulatory path is mapped. The bilateral volume already exists. The rails do not. We are building them.
The right question for any market-infrastructure bet is not 'is this idea good?' It is 'is this the moment?' For orbit, it is.
Keep reading
The four forcing functions, with citations and dates.
The thesis page argues why now in summary. The why-now page walks each of the four forcing functions with sources, dates, and the empirical signals that make them concrete.