On October 21, 2026, the Federal Communications Commission (FCC) approved the transfer of control of TLG Unpaired Holdings, LLC, which holds three unused AWS-3 spectrum licenses, to Starlink Spectrum Holdings, LLC, a SpaceX subsidiary. The order waived terrestrial construction requirements for those licenses but made that relief conditional on performance milestones for SpaceX’s planned direct-to-device (D2D) system.
What the FCC approved
The FCC approved a change in control of the license-holding company, not an award of newly auctioned spectrum. Starlink Spectrum Holdings will acquire all outstanding membership interests in TLG Unpaired Holdings. TLG will then become a direct, wholly owned subsidiary of Starlink Spectrum Holdings and an indirect subsidiary of SpaceX.
The FCC said the licenses would otherwise return to its inventory for possible reauction at an unspecified future date. It found that approving the transfer with enforceable buildout conditions served the public interest. The applicants told the FCC that Tristar had planned to use the licenses for terrestrial service connected to EchoStar’s 5G network, but that plan became untenable after EchoStar assigned spectrum licenses to SpaceX.
For context on the separate, system-level authorization, see NeoTeo’s earlier coverage of the FCC’s approval for SpaceX’s Starlink Mobile satellite system. The October 21 order concerns control of TLG and its AWS-3 licenses.
The licenses cover 62 counties across eight states
The three unpaired AWS-3 licenses cover 62 counties, all or parts of 28 Cellular Market Areas, across eight U.S. states. The FCC put the area at approximately 4% of the U.S. population. These are license-area figures, not a measure of Starlink Mobile customer coverage.
The FCC describes the spectrum as ranging from 1695 to 1710 MHz and applies uplink requirements to it. The commission said the licenses could help SpaceX assemble a geographically contiguous AWS-3 footprint for 5G, D2D, or a combination of the two.
FCC’s staged D2D uplink requirements
The FCC set three minimum uplink-throughput milestones. Each is measured at the fifth percentile, a lower-end performance measure rather than a peak-speed target, across more than 90% of the license area.
| Milestone | Minimum uplink throughput at the fifth percentile | License area | Service availability | Deadline |
| First interim | 100 kbps/MHz | More than 90% | 70% of the time | November 30, 2029 |
| Second interim | 200 kbps/MHz | More than 90% | 80% of the time | November 30, 2031 |
| Final | 300 kbps/MHz | More than 90% | 90% of the time | November 30, 2036 |
The order also sets a separate spectral-efficiency requirement of 100 kbps/MHz/beam at the first interim milestone and 200 kbps/MHz/beam at the final milestone. SpaceX must file a construction notification within 30 days of each milestone and provide supporting technical documentation. It must submit customer-service measurements or data within six months of each milestone.
Missing the first interim requirement moves the final deadline forward by one year. Missing the second moves it forward by two years, cumulative with any first-milestone acceleration. If SpaceX fails to meet all final buildout requirements for a license, that license automatically terminates.
What the construction waiver means
The FCC waived terrestrial construction requirements and the original construction deadlines for these three licenses, subject to the D2D milestones. The waiver removes buildout duties attached to these licenses; it does not bar SpaceX from using terrestrial infrastructure elsewhere in Starlink Mobile’s wider network.
The throughput targets are license-area uplink obligations, not retail per-user download-speed guarantees. The order ties the construction waiver to measurable performance and reporting requirements, with missed milestones capable of accelerating the final deadline or terminating an affected license.
