Space Interests Excited About FCC's Part 100 Rules Proceeding
The commercial space sector is bullish on the major overhaul of satellite and earth station licensing that the FCC Space Bureau is considering, space advocates said Monday during an FCBA webinar. However, multiple speakers cautioned that the FCC's efforts to speed up approvals could be undercut if there aren't improvements to federal agencies' coordination with private operators about spectrum use. Commissioners unanimously adopted the space modernization NPRM in October (see 2510280024).
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Space Bureau Associate Division Chief Greg Coutros said the revamp is a recognition that the FCC's current Part 25 rules, which govern satellite licensing, worked well for a time but weren't keeping up with the growing volumes of applications or the new operations that the agency is handling. The bureau saw 295 satellite applications and 3,000 earth station applications in 2024, versus 124 and 974, respectively, a decade earlier, he said. The Part 25 rules were made for bespoke reviews, an approach that "just does not work now."
In addition, Coutros said the Part 100 rules in the NPRM propose "radical changes," such as allowing expedited approvals for applicants that can certify that they meet bright-line requirements and shifting earth station licensing to predominantly blanket licenses. It's a drain on FCC and operator resources to file essentially duplicate applications for largely identical earth stations, he said.
The length of time needed to get applications processed and to deal with the spectrum coordination process is an issue frequently raised by Satellite Industry Association members, President Tom Stroup said.
Danielle Pineres, Planet Labs' vice president of regulatory affairs and compliance, also said the wait to get a license reviewed and approved remains a chief concern for operators. It often takes more than a year for significant application approvals, and during that time engineers might make notable changes to the proposed system, she said.
Clearly defined rules would let engineers design to standards that pass FCC muster, Pineres argued. The satellite industry sometimes struggles with license conditions that feel above and beyond FCC rules, she said, making it unclear how to make design changes. For example, while the commission's rules don't define aggregate reentry risk, the agency will sometimes withhold an authorization until an operator improves its aggregate risk metric. Pineres added that once the FCC moves into a Part 100 rules world, there's hope it will lay out a path for addressing some legacy conditions on previously granted licenses.
Stellar Frequencies CEO Peter Dohm said Part 25 rules haven't caught up with in-space servicing, assembly and manufacturing (ISAM) capabilities, so a lot of that activity is stuck with Part 5 experimental licenses. The Part 100 rules should help close that ISAM gap, he said. Dohm also expressed hope that the Part 100 rules might be a model for other agencies like NTIA and NOAA on how to expedite their own approvals.
Pineres noted that the frequencies that earth observation operators typically use are shared with the federal government, and the coordination process is lengthy and frequently opaque. NTIA knows it's an issue and is working on addressing it, she said.
Wiley space lawyer Shiva Goel said federal operations in the S and X bands represent the lion's share of hangups about spectrum coordination. He cited manpower as one spectrum coordination challenge that federal agencies are facing, since staffers working on spectrum have additional duties. It can also be tough to get agencies to look holistically at applications and consider the rewards to the public and not just the risks it poses to the agency's mission, he said.
Pineres said the Part 100 rules' move toward a more modular approach, where some pieces of an application could be expedited, and away from big, narrative-based applications should make FCC staffers' work easier. A modular process that allows noncontroversial parts of an application to move forward could enable a launch, even if more complex or controversial aspects get held for future consideration, she said.
Speakers also discussed how the FCC's current Part 25 approach, and its move to Part 100 rules, will need better underlying IT.
Pineres said the proposed modification of market access grants envisioned in the NPRM could help make the U.S. a hub for commercial ground station activity. The U.S. requires market access approval not just to serve U.S. customers but to communicate with U.S. ground stations for needs such as telemetry, tracking and control, while other nations typically separate the two, she noted. The NPRM proposes a similar separation. Stroup added that there's some disagreement among carriers about the issue.
Dohm said it's unclear if the pending ISAM proceeding before the FCC will close with the Part 100 rules adoption or if the agency will keep it open to collect more information about ISAM.
Beyond the Part 100 rules, Stroup said, the FCC needs to clarify how the Commerce Department's traffic coordination system for space will affect the commission's handling of orbital debris issues.