Why now · Five forcing functions
Five forcing functions, all dated within the last eighteen months.
Updated
May 2026
Most recent forcing function
FCC EPFD · April 30 2026
Bilateral spectrum volume
$28B / 18mo
Posture
Cited, dated, footnoted
At a glance
The five numbers worth memorising.
Spectrum bilateral volume · 18 months
$0B
Direct-to-device spectrum deal flow ending Q1 2026 — the volume Wavestar would clear, already crossing today.
FCC EPFD vote · 2026
Apr 30
FCC modernised NGSO/GSO interference protections — voluntary private bargaining is now the regulatory default.
FCC accepts SpaceX ODC
Feb 4
DA 26-113 — Space Bureau accepted SpaceX's filing for ~1M orbital-DC satellites. Starcloud filed for 88,000 the day before.
Azure Orbital · GSaaS exit
2024
Microsoft retired Azure Orbital, fragmenting the ground-station market and accelerating bilateral coordination demand.
SDA optical standard · live
2025-26
The Space Development Agency's optical comms standard makes ISL capacity fungible across constellations for the first time.
Forcing function 1
The FCC opened private bargaining for orbital spectrum coordination.
On April 30, 2026 — five days before this page was first published — the Federal Communications Commission voted to modernise the EPFD (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. The Order applies to current NGSO licensees, market-access grantees, pending applicants, and every future applicant.
That is the regulatory door. The FCC has just told the orbital spectrum industry that private coordination is the path forward — and a private coordination market without post-trade infrastructure is bilateral, opaque, and operationally expensive. The infrastructure to make it cleared, neutral, and auditable is what Wavestar is.
The FCC's own estimate for the value unlocked by the modernisation is in excess of $2 billion in economic benefit and a sevenfold increase in space-based broadband capacity. That number assumes someone builds the coordination layer underneath. We are that layer.
NGSO and GSO operators can bargain for appropriate interference protections through voluntary, private agreement.
Forcing function 2
$28 billion in bilateral spectrum deal flow over eighteen months.
Direct-to-device spectrum is being acquired, swapped, and contested at scale today. AST SpaceMobile and Verizon. SpaceX and T-Mobile. Globalstar with Apple and the reported Amazon interest. The headline transactions are the visible part of a substantially larger long tail of bilateral coordination between operators, telcos, and integrators.
Bloomberg's Ed Ludlow has reported that Amazon's interest in Globalstar is fundamentally about the spectrum, not the satellites. Spectrum is a regulated, scarce, and globally harmonised asset that cannot be replicated. It is being recognised as the prize. The volume that crosses bilaterally today is the volume that needs clearing tomorrow.
None of this transaction flow is cleared. There is no neutral price discovery. There is no standardised contract. There is no netting. Counterparty risk is handled bilaterally by every pair of operators, every time. This is what unbundled-but-unmatured markets look like in the eighteen months before a clearing house arrives.
Representative deal taxonomy
- AST · Verizon
- DTC capacity
- SpaceX · T-Mobile
- DTC capacity
- Globalstar · Apple
- DTC capacity
- Amazon · Globalstar
- Acquisition talks
- Long tail
- Bilateral, opaque
Forcing function 3
Ground-station fragmentation accelerated when Microsoft exited.
Microsoft retired Azure Orbital in 2024. EQT acquired Eutelsat's ground-station assets the same year. AWS, KSAT, Leaf Space, Atlas Space, RBC Signals, and Infostellar are vertically integrating — each pulling operators into a proprietary stack that does not interoperate cleanly with the others.
The Ground Station as a Service market is small in absolute terms — credible estimates range from $0.5B to $1.4B in 2024, growing at 15-19% CAGR — but it is the most legible piece of bilateral capacity coordination in orbit today. The fragmentation makes a neutral coordination layer between operators and ground infrastructure both necessary and possible.
Vertical integration without interoperability is exactly the gap a neutral clearing layer fills. Operators are already paying the coordination tax bilaterally; the post-trade infrastructure that makes it cleared, neutral, and auditable is what becomes inevitable underneath. The fragmented operator-and-ground-station seam is where the v1 cleared downlink market lives.
Azure Orbital was retired in 2024, the same year GSaaS interest accelerated following EQT's acquisition of Eutelsat's ground-station assets.
Forcing function 4
SDA's optical comms standard made cross-constellation ISL fungible.
More than 5,000 optical space terminals were operational in orbit by the end of 2024, up from roughly 600 in 2018. Over 70% of the LEO satellites launched globally now feature optical inter-satellite links. The substrate is real and deployed.
What changed in the last twelve months is standardisation. The Space Development Agency's optical comms standard has become the compliance reference across both military and commercial terminals. Kepler launched its commercial optical data relay constellation in January 2026 with explicit SDA-compatibility, serving 2.5 Gbps on-demand downlink. Cross-constellation ISL capacity is now technically fungible.
Fungibility is the prerequisite for a clearable wholesale market. ISL capacity is not yet trading wholesale at scale — most volume is constellation-internal — but the substrate is ready and the standard is locked. ISL is adjacent to the live wedge today; it will be a clearable asset class on a 2-3 year horizon.
Optical mesh substrate · 2024
- Optical terminals on orbit
- 5,000+
- LEO satellites with OISL
- 70%+
- SDA-compliant
- Standardised
- Kepler commercial relay
- Live · Jan 2026
- Throughput · per terminal
- Up to 2.5 Gbps
Forcing function 5
Orbital compute went commercial — and the largest stack vertically integrated.
In November 2025, Starcloud launched the first NVIDIA H100 into orbit. In December, the same satellite ran the first in-orbit large language model and performed the first in-orbit LLM training run. On February 4, 2026, the FCC's Space Bureau accepted SpaceX's filing for an orbital data-center system of up to one million satellites (DA 26-113); Starcloud filed for an 88,000-sat constellation the day before. By April 13, 2026, TechCrunch reported the largest orbital compute cluster open for business.
The merger of SpaceX with xAI and Starcloud's published compute partnership with Anthropic created the shape of the orbital compute market that follows: two vertical stacks. One Musk-aligned, one NVIDIA-anchored. Both will route compute intra-firm where they can. The other half of the demand — hyperscalers procuring outside their own footprint, defense and intelligence buyers requiring jurisdictional neutrality, sovereign AI programmes, ground-station operators settling downlink against compute output — needs a neutral CCP.
Compute is the demand catalyst that pulls every other Wavestar market forward. Every Compute-Hour delivered creates a downlink-minute of egress, an ISL-Gbps-hour of training-fabric backhaul, a Ku/Ka spectrum-hour, a hosted-payload slot, and a recurring propellant/ISAM demand for the constellation that hosts it. The Compute-Hours market lives at /markets/orbital-compute.
Compute substrate · 2025-26
- First H100 in orbit
- Nov 2025
- First in-orbit LLM training
- Dec 2025
- FCC accepts SpaceX ODC
- DA 26-113 · Feb 4 2026
- Starcloud Series A
- $170M · $1.1B val
- Largest cluster commercial
- Apr 2026
- Vera Rubin Space Module
- Oct 2026
The cumulative effect
What the five functions do, together.
- 01
The market exists already
$28B of bilateral volume is the empirical answer to the demand question. Wavestar is not creating a market — it is clearing one that is already trading. - 02
The regulator opened the door
FCC EPFD modernisation gives spectrum coordination a private-bargaining regime. Bilateral coordination becomes a market the moment private bargaining is endorsed. - 03
The incumbents are not coming
Azure Orbital exited GSaaS in 2024. AWS is locked into its own stack. The neutral coordination layer is missing — and the largest cloud provider already chose not to build it. - 04
The substrate is standardised
SDA's optical standard makes cross-constellation capacity fungible. Fungibility is the precondition for clearable wholesale. The technical floor is now in place. - 05
Compute is the demand catalyst
Orbital compute went commercial in April 2026. The two largest stacks vertically integrated. Compute pulls demand for downlink, ISL, spectrum, hosted-payload, and propellant — and the half of the demand that lives outside the integrated stacks needs a neutral CCP.
Timeline
When the five flipped.
- 2024 · Q3Complete
Microsoft retires Azure Orbital
GSaaS market fragments. EQT acquires Eutelsat ground-station assets the same year. The neutral coordination layer becomes a structural gap. - 2024-25 · ContinuousComplete
$28B in spectrum bilateral deal flow
Eighteen months of direct-to-device spectrum transactions accumulate without post-trade infrastructure underneath them. - 2025 · H2Complete
SDA optical comms standard reaches commercial compliance
Cross-constellation ISL capacity becomes fungible for the first time. Kepler aligns its January 2026 commercial launch to the SDA standard. - 2025 · NovemberComplete
First NVIDIA H100 in orbit · Starcloud-1
The orbital compute substrate goes operational. December 2025: first in-orbit large language model and first in-orbit LLM training. - 2026 · February 4Complete
FCC accepts SpaceX orbital-DC filing · DA 26-113
1M-satellite orbital data-center system accepted for filing. Starcloud filed for 88,000 the day before. The category becomes regulatorily real. - 2026 · April 13Complete
Largest orbital compute cluster open for business
Starcloud begins commercial sales. Vertical-integrated stacks (SpaceX↔xAI, Starcloud↔Anthropic) make the case for a neutral CCP themselves. - 2026 · April 30In progress
FCC EPFD modernisation Order adopted
Voluntary private bargaining replaces fixed regulatory protections for NGSO/GSO interference coordination. The regulatory door opens. - 2026 · MayIn progress
Wavestar onboards design-partner cohort
Spectrum operators, ground stations, constellation operators, and compute providers. Including the Compute-Hours working group convening Starcloud, NVIDIA, Crusoe, hyperscalers, and frontier labs.
The wedge that follows from this
Spectrum is loudest. Downlink ships first. Compute is the catalyst.
The market signal is loudest in spectrum. The simplest unit of bilateral capacity to authenticate, clear, and settle is the downlink minute — so it is what the v1 cleared market is. Compute-Hours are the emerging demand catalyst that pulls every other market forward. The unbundling thesis is the same across all three.