Live signal · Loudest bilateral volume
Spectrum-hours. $28 billion of bilateral volume. The FCC just opened the door.
Bilateral volume · 18mo
$28B
FCC EPFD vote
Apr 30 · 2026
2030 addressable spend
$20B
Settlement
T+0 atomic · USDC
What just happened
April 30, 2026 — the regulatory door opens.
- 1995-2025Complete
Fixed EPFD regime
Article 22 of the ITU Radio Regulations and FCC's Section 25.146 imposed fixed power-flux-density limits on NGSO/GSO interference. The framework was static, hard-coded, and increasingly out-of-step with mega-constellation density. - 2024-26Complete
FCC review and NPRM
The Commission opened the EPFD modernisation rulemaking. Industry response was extensive; mega-constellation operators, GSO incumbents, and direct-to-device entrants all filed positions. The final order picked private bargaining as the path forward. - April 30 · 2026In progress
FCC adopts the EPFD modernisation Order
Voluntary private bargaining replaces fixed regulatory protections. NGSO and GSO operators can negotiate interference protections privately. The FCC retains backstop authority but the default is private agreement. - May 2026 onwardIn progress
Wavestar opens design-partner cohort for spectrum
Spectrum operators, ground stations, and constellation operators. Standard contract specifications drafted in lockstep with the FCC's implementation guidance. Cleared market opens as the SEC ATS-N filing goes operative.
The bilateral volume
$28 billion in eighteen months — and that is just the headlines.
AST SpaceMobile and Verizon. SpaceX and T-Mobile. Globalstar and Apple. The reported Amazon interest in Globalstar — which Bloomberg's Ed Ludlow has framed as fundamentally about the spectrum, not the satellites. Each of these is a multi-billion dollar bilateral arrangement that is settled by lawyers, not clearing houses. Each is opaque to every counterparty except the two that signed it.
Spectrum is being recognised as the prize. It is regulated, scarce, globally harmonised, and irreplicable. The long tail of operator-to-operator coordination beneath the headline deals is what the EPFD modernisation just legitimised. The pattern that emerges is a market shape — many counterparties, heterogeneous units, bilateral coordination — that is exactly the shape a cleared market is built for.
We do not invent the contracts. We standardise the units that are already trading. The MHz-hour over a named ITU coordination zone is the atom; every cleared lease is a bundle of those atoms with explicit start, end, band, and authorisation reference. The bilateral market is already trading in roughly this shape; we make it cleared, neutral, and auditable.
Representative direct-to-device deals
- AST · Verizon
- DTC capacity
- SpaceX · T-Mobile
- DTC capacity
- Globalstar · Apple
- DTC capacity
- Amazon · Globalstar
- Acquisition talks
- Long tail
- Bilateral, opaque
The reconciliation
Spectrum is the loudest signal. Downlink ships first.
Spectrum is the loudest signal of bilateral commodity volume in the orbital economy today. $28B in eighteen months. FCC EPFD modernisation. The largest, fastest-moving, most-public coordination market in orbit.
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 — countable, deliverable, and contestable. So downlink is what the v1 cleared market is. Spectrum follows as the SEC ATS-N filing goes operative and the FCC's EPFD-private-bargaining regime matures.
Both are the same unbundling thesis. The two markets reinforce each other — the regulatory path that licenses one licenses the other; the attestation framework that signs one signs the other; the operator who clears spectrum will clear downlink, and vice versa. The order of cleared-market launches is the order in which we open the books, not a hierarchy of importance.
The choice is not between spectrum and downlink. It is the order in which we open the cleared books.
What you trade
1 MHz × 1 hour over a defined ITU coordination zone.
- 01
Unit of trade
1 MHz × 1 hour over a named ITU coordination zone, bound to the lessor's authorised frequency band, coverage area, and orbit class. - 02
v1 scope — short-term lease
Leases ≤ 30 days on rights the lessor already holds under ITU SNS + FCC IBFS (or equivalent national administration). No new authorisation required. - 03
v2 scope — long-term transfer
Multi-year transfers require regulatory consent in most jurisdictions. Activates after Wavestar's SEC ATS-N registration clears. - 04
Coordination zone
Zones are defined by ITU Region (Region 1/2/3), orbital shell (LEO/MEO/GEO), and frequency band. A lease is valid only within its named zone. - 05
Attestation
Independent RF monitoring — NSR Kratos, Analytical Graphics ComSpOC, national regulator monitoring networks — signs the actual occupancy. Wavestar reconciles against the registered lease. - 06
Filing reconciliation
Every cleared lease mirrors into ITU SNS correspondence and FCC IBFS records (or the relevant national administration's system) via a daily reconciliation feed.
Contract specification
Spectrum-Hour (SPEC) · Rulebook exhibit 4.8.5.
SPEC · Short-term lease contract
- Ticker
- SPEC · [band] · [coord-zone] · [hour]
- Unit of trade
- 1 MHz × 1 hour within a named ITU coordination zone
- Lease tenor
- 1 hour minimum · 30 days maximum (v1)
Long-term rights transfer (> 30 days) activates in v2 after SEC ATS-N clears.
- Tick size
- $2 per MHz-hour
- Minimum block
- 50 MHz-hours
Matches common short-term coordination scheduling granularity.
- Delivery attestation
- Independent RF monitoring signature + ITU SNS / FCC IBFS reconciliation
- Settlement
- T+0 · atomic · USDC primary · Fedwire / SWIFT optional
- Initial margin
- 15%
Reflects counterparty risk on continuing authorisation validity during lease term.
- Variation margin band
- 4%
Daily mark on cleared curves per named coordination zone and band.
- Prohibited pairs
- OFAC · national-security · end-use controls
Every counterparty pair is screened on match. Cross-border leases carry additional authorisation checks.
- Position limit
- 5% of cleared zone open interest per lessee; 25% per lessor
Market dynamics
From bilateral OTC to cleared book.
Reference price · Ka · Region 2
$3.50 / MHz-hr
Rolling 30-day midpoint; Ka-band leases in ITU Region 2 are the primary activation liquidity.
Cleared zones
0
Coordination zones live by M4. 2030 steady state targets all ITU regions × all commercial bands.
Avg lease tenor
14 days
Design-partner target. Short-leg leases concentrate around launch, commissioning, and contingency windows.
Reconciliation cadence
Daily to ITU + FCC
Every cleared lease mirrors into SNS correspondence and IBFS records within 24 hours. Divergence is an alert.
Counterparties and observers
Operators, regulators, RF monitors.
- LES
Lessors
Operators with surplus authorised capacity. GEO fleet operators with underused transponder inventory are a large early source; LEO broadband constellations supply shorter-window leases. - LEE
Lessees
New-entrant fleets, contingency-access buyers, government and civil agencies needing short-term coverage, and brokers aggregating leases for downstream resale. - ITU
ITU · Bureau of Radiocommunication
Master International Frequency Register is the authoritative source. Wavestar mirrors entries and reconciles cleared leases daily. See /regulatory/itu. - FCC
FCC · International Bureau
IBFS is the U.S. authorisation system of record. The April 30 2026 EPFD modernisation Order applies. Wavestar reconciles lease state nightly. See /regulatory/fcc-ibfs. - MON
RF monitoring observers
NSR Kratos, AGI / Ansys ComSpOC, and comparable providers operate independent monitoring networks whose signatures form the Attest quorum on actual occupancy. - NAT
National administrations
Ofcom (UK), Bundesnetzagentur (Germany), MIC (Japan), ANATEL (Brazil), and others hold analogous filing records; leases touching their territory reconcile into their system as well.
Regulatory context
The new regulatory default is private bargaining.
- FCC EPFD Order · April 30 2026
- Voluntary private bargaining = default
NGSO/GSO interference protection now flows through private agreement. Order applies to current licensees, market-access grantees, pending applicants, and future applicants.
- ITU Radio Regulations
- Lease lives inside the lessor's assigned rights
v1 leases do not constitute a transfer under Article 5, Article 11, or Article 23 of the Radio Regulations. They are short-term use-rights granted by the filing operator.
- FCC Part 25
- Filing operator retains Part 25 licence
Part 25 authorisations are non-transferable without FCC consent. Wavestar's v1 scope is leasing of use-rights under the existing Part 25 licence.
- SEC ATS-N
- Filing underway · long-term transfers activate post-clearance
Long-term rights transfers — v2 scope — require the SEC Alternative Trading System registration. Filing status at /regulatory/sec-ats.
- National export controls
- Counterparty screening on every match
OFAC, Commerce BIS entity list, and equivalent national lists are screened on every match. Cross-border leases carry additional authorisation checks before release.
- Sanctions posture
- Hard-block on prohibited counterparties · per /compliance/sanctions
No cleared lease between sanctioned counterparties. Pending-status entries blocked pending counsel review.
Spectrum is a regulated, scarce, globally harmonised asset that cannot be replicated. The bilateral market exists. The regulator opened the door. The post-trade infrastructure is what we are.
Spectrum cohort · M4
Operators clearing the first $10M of cleared lease notional pay zero fees.
Design-partner lessors clear zero-fee through the first $10M of short-term lease notional. RF-monitoring partners earn observer stipends per attested lease. Long-term transfer book opens after SEC ATS-N goes operative.