Space Interests Urge Shot Clock Use and Target FCC Rules That Exceed ITU's
Some space operator interests, including SpaceX and the Commercial Space Federation, are keen on shot clocks for satellite and earth station licensing determinations, according to docket 25-133 filings posted Monday in FCC Chairman Brendan Carr's "Delete" proceeding. Space industry filings also included several companies targeting technical rules and requirements. Other "Delete" proceeding submissions presented deregulatory ideas from telecom, broadcast and cable interests (see 2504140046 and 2504140063).
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
Quit requiring long-form legal and technical narratives in space applications and let operators self-certify compliance with FCC rules, said the Commercial Space Federation. In addition, the FCC should create a default presumption that satellite or earth station license applications that comply with agency rules would serve the public interest and be granted, it said, adding that shot clocks would end open-ended licensing proceedings. The group also called for satellite system operators to be able to modify their systems without agency approval in cases when the modification continues to comply with FCC rules.
In addition to backing shot clocks, SpaceX said U.S.-based space companies seeking licenses from foreign jurisdictions should have to withdraw any related U.S. market access applications and instead file those applications and U.S. satellite applications for new systems. SpaceX said the FCC should reject -- “except in extremely rare and truly unforeseeable circumstances” -- extensions of non-geostationary orbit (NGSO) deployment milestones. Satellites deployed after the milestone date should be treated as a new system in a subsequent processing round, it said.
Amazon’s Kuiper called for axing the limits on fixed satellite service to individually licensed earth stations using the 37.5-40 GHz band, saying earth stations in that band receive transmissions from space stations and don’t impose interference risks to other services. It also listed a set of NGSO mobile satellite service feeder link restrictions that it said were outdated and should be eliminated. Kuiper also said rules for changing coordinates of licensed earth stations without notification are “overly burdensome” and urged removing the in-orbit testing and filing requirement, saying such notifications are impractical for mega constellations that continually launch, test and orbit-raise satellites.
Intelsat targeted a variety of FCC rules that it said were more restrictive than ITU statutes, including the agency’s 0.05-degree station-keeping requirement and its 2-degree spacing rule. Intelsat said the FCC's bond requirements are no longer needed to prevent spectral and orbital resource warehousing, since the agency is looking to extend regulatory fees to authorized but not operational satellites.
Kepler Communications took aim at the 180 kilograms-per-satellite cap in the streamlined small satellite licensing procedure, arguing that “otherwise suitable systems are excluded from streamlined licensing procedures … because they exceed an outdated mass threshold that no longer reflects the technical and operational realities of the industry.”
The Satellite Industry Association said the FCC should drop the requirement that Space Bureau applications provide emission designators, saying that it's “a constant source of confusion and potential errors.” The group said that, as far as it knows, no one has filed comments or a petition to deny based on emission designators. It also called for streamlining the coordination process between federal and non-federal users of shared spectrum bands. The pre-coordination process between commercial operators, federal government spectrum users in shared bands and NTIA “is neither clear nor publicly documented in any detail.”
One route to easing regulatory burdens would be to allow a change under an existing authorization as long as there’s no compelling reason not to, Telesat said. With the FCC’s Part 25 satellite rules, that would mean more scenarios allowed under Section 25.118’s modifications not requiring prior authorization, it said. NGSO operators by default should be able to distribute satellites among planes, make minor altitude changes or increase the satellite count by a small number without prior authorization, it added.
To accommodate hybrid air-launch and suborbital human operations, the FCC should modify the power-level restrictions on transmission during the first stage of launches, Virgin Galactic said. It also recommended that the agency change its definition of “telemetry,” which, it said, restricts its ability to stream audio and video intended for internal use.