Abstract: As reported in a companion work, in its first phase, NASA’s 2015 highly elliptic Magnetospheric Multiscale (MMS) mission set a record for the highest altitude operational use of on-board GPS-based navigation, returning state estimates at 12 Earth radii. In early 2017 MMS transitioned to its second phase which doubled the apogee distance to 25 Earth radii, approaching halfway to the Moon. This paper will present results for GPS observability and navigation performance achieved in MMS Phase 2. …