Space

In a recently published Notice of Proposed Rulemaking (NPRM), the FCC has proposed a major overhaul of the rules governing use of the Upper Microwave Spectrum.  The notice proposes rules designed to encourage more intensive use in the bands collectively known as the Upper Microwave Flexible Use Service (UMFUS) bands, which are jointly shared by…

Continue Reading FCC Proposes Overhaul of Upper Microwave Spectrum Rules

As part of the Federal Communications Commission (FCC)’s “Space Month” initiative, the FCC has released a Notice of Proposed Rulemaking (NPRM) designed to overhaul the existing framework for space and earth station licensing.  The FCC’s stated goal is to create the “friendliest regulatory environment in the world” for the space industry.

The proposed framework would…

Continue Reading FCC Proposes “Space Modernization for the 21st Century”: Key Highlights for Industry and Stakeholders

Chairman Brendan Carr of the Federal Communications Commission (FCC) recently declared October 2025 as ‘Space Month’ at the FCC.  As part of the FCC’s Build America Agenda, the FCC is scheduled to vote on two proposals aimed at modernizing the agency’s regulatory framework for space innovation in the country.  These proposals represent another step…

Continue Reading FCC Launches ‘Space Month’ Agenda

On July 17, 2025, the FCC released a discussion draft of a Report and Order (R&O) that, if adopted, would streamline processing of satellite and earth station applications and make other changes to satellite-related license requirements.  The Commission is scheduled to vote on the R&O – which may be subject to further modifications prior to the vote – at the Open FCC Meeting scheduled for Thursday, August 7, 2025.  Below is a high-level summary of some key changes included in the draft R&O.

  • New Flexibility in Adding Satellite Points of Communication.  The R&O creates a new type of earth station license ─ a “baseline license” ─ that would not require an earth station operator to specify satellite points of communication for the earth station in the initial application.  After receiving its baseline license, an operator could then flexibly add satellite points of communication (i.e., new satellites with which earth stations can communicate) as needed.  Notably, the R&O also would modify the process for adding a point of communication to allow for communications “immediately upon both filing notice . . . and pay[ing] the filing fee.”  This streamlined process means that the notice would be effective unless the FCC acted within 15 days after the filing fee is paid to review and remove the new point of communication. 
    • In addition to streamlining modifications for existing earth station licenses, this revision is intended to support the Ground-Station-as-a-Service (“GSaaS”) business model, whereby “a neutral host establishes connectivity to multiple satellite systems in space.”

Continue Reading FCC Releases Draft Report & Order Streamlining Satellite Licensing Processes

On 25 June 2025, the European Commission (“EC”) announced its long-awaited proposal for a Regulation on the safety, resilience, and sustainability of space activities in the EU (the “Draft EU Space Act” or “Draft EUSA”). The Draft EUSA proposes to impose obligations on providers of “space services,” which are:

  • The operation and control of human-made objects sent to space;
  • The provision of space launch services;
  • Services provided by “primary providers of space-based data,” a term covering providers that carry out the first processing of either communications data or observation data received from outer space (which may include electronic communications service providers);
  • In-space services and operations; and
  • Collision-avoidance services.

Most of the obligations in the Draft EUSA would apply to providers of space services that are located in the EU, and those located outside the EU but that provide services to space operators in the EU. However, the rules on safety described below would apply to space objects that generate data or enable the provision of space services in the EU. These rules, and certain rules on collision avoidance, would also apply to space objects that at or lower than a geostationary orbit.

The explanatory memorandum notes that 13 EU Member States have passed national legislation related to space, which creates the risk of a fragmented internal market for the space sector. The Draft EUSA therefore establishes rules in four main areas in an attempt to harmonize the law relating to this sector, namely authorization and registration requirements, and obligations to ensure safety, resilience, and sustainability of space services. We describe these in more detail below.Continue Reading The European Commission announces a proposal for the first EU Space Act

On December 27, 2024,  the National Telecommunications and Information Administration (NTIA) issued a Request for Comment (“RFC”)that seeks public input on the potential impacts on the Global Positioning Satellite (GPS) L1 signal by the growth of satellite-based direct-to-device (D2D) operations that use frequencies between 1610-1660.5 MHz (the “L-band”).   As the lead spectrum advisor to the Executive Branch on spectrum issues, NTIA serves as the advocate for other agencies including the Department of Transportation (DOT) before the FCC.  NTIA issued its Request for Comment (RFC) in response to analysis prepared by DOT and states that its interest in D2D usage stems from the increasing deployment of services in which mobile devices like smartphones and Internet of Things (IoT) devices connect directly to satellite systems in the L-band, a portion of which is located near spectrum allocated to GPS.  NTIA invited comments to be filed by February 10, 2025. Continue Reading NTIA Seeks Comment on Potential Effects of Satellite Direct-to-Device Operations in the L-band on GPS L1 Signal

On December 31, 2024, the FCC issued a Report and Order (Third R&O) formally allocating additional spectrum for commercial space launch applications, fulfilling a provision of the Launch Communications Act (LCA) of 2024.  The LCA, which President Biden signed on September 26, 2024, directed the FCC to make the 2025–2110 MHz, 2200–2290 MHz, and 2360–2395 MHz bands (LCA Bands) available for use in commercial launches and reentries, and to finalize such allocations within 90 days of enactment of the bill.  In a statement on December 19, 2024, FCC Chairwoman Rosenworcel stated that the new rules are intended to “build upon Commission action in 2023 that will enable companies to conduct launch activities without needing to request temporary authority from the FCC for each space launch,” making the commercial space launch process more predictable.

The FCC states that the rule changes, which are part of the agency’s new Space Innovation agenda, allocating new spectrum in the 2360–2395 MHz band generally are intended to satisfy the Congressional mandate of the LCA, provide regulatory certainty to licensees, minimize administrative burdens by leveraging efficiencies of scale and scope that will spur innovation, investment, and rapid deployment of space launch operations, and protect incumbents from harmful interference.Continue Reading FCC Allocates New Spectrum for Commercial Space Launches

On December 5, 2024, the Federal Communications Commission (FCC) announced that its filing requirements were now in place for parties seeking to deploy Supplemental Coverage from Space,  finalizing a new regulatory regime that enables satellite operators to work with wireless provider partners to provide ubiquitous coverage to hard-to-reach users.  This step establishes the administrative requirements for FCC approval of SCS deployments and follows on the heels of a November 26th authorization of the first-ever SCS partnership, a collaboration between SpaceX and T-Mobile.Continue Reading FCC Issues Filing Guidelines for Supplemental Coverage from Space (SCS) Applications; Authorizes SpaceX and T-Mobile to Premiere SCS Deployment

Last week, the Federal Communications Commission (“FCC”) issued new guidance and adopted new rules intended to expedite the processing of satellite and earth station license applications.  In a corresponding move, the agency adopted a Further Notice of Proposed Rulemaking (“FNPRM”) seeking comment on additional policy changes concerning satellite and earth station licensing.  These actions, which are part of the FCC’s new Space Innovation agenda, highlight the agency’s ongoing commitment to increasing its role in the regulation of a growing commercial space economy. This latest space-related FCC action consists of two parts: (1) a Report and Order (“R&O”) issuing new guidance and adopting new rules concerning the Space Bureau’s processing of satellite and earth station license applications, and (2) an FNPRM proposing further policy changes. 

This latest space-related FCC action consists of two parts: (1) a Report and Order (“R&O”) issuing new guidance and adopting new rules concerning the Space Bureau’s processing of satellite and earth station license applications, and (2) an FNPRM proposing further policy changes. Continue Reading FCC Takes Action to Expedite Satellite Licensing as Part of Agency’s Space Innovation Agenda

Updated April 12, 2023. Originally posted March 23, 2023.

In March, the Federal Communications Commission (FCC) adopted a Notice of Proposed Rulemaking (NPRM) that seeks public comment on a proposed licensing framework that would enable multiple satellite operators to supplement the network coverage of terrestrial wireless service providers.  Termed “Supplemental Coverage from Space” (SCS), this service would authorize certain satellite systems to use spectrum licensed to a terrestrial network provider partner to provide expanded coverage to the provider’s wireless customers, even in remote areas. Comments on the NPRM, which appeared in today’s Federal Register, are due Friday, May 12, with reply comments due the following month, on Monday, June 12.Continue Reading FCC Seeks Comment on “Supplemental Coverage from Space” Rules, Responding to Growing Trend towards Partnerships between Satellite Operators and Wireless Network Providers