Why It Matters

The Federal Communications Commission is proposing rules that would let space companies change satellite operating parameters within approved limits without seeking additional permission and require a U.S.-based control point for all FCC-licensed space stations. ​

The broader licensing overhaul covers an estimated 3,335 entities, 130 space station licensees and 3,205 earth station licensees, and advances the objectives of Executive Order 14369, "Ensuring American Space Superiority," signed in December 2025. The proposal builds on a July Report and Order that replaced the prior 47 CFR Part 25 satellite licensing framework with a new Part 100 and addresses issues the commission left open at that stage.

The Big Picture

The Further Notice of Proposed Rulemaking (FNPRM) revisits issues the Commission declined to resolve in the July order, including earth station antenna performance standards, off-axis equivalent isotropically radiated power (EIRP) density limits and Nationwide, Non-Site licenses, following an October 2025 notice that drew comments from approximately 86 parties. The FCC classifies the broader regulatory action as deregulatory under Executive Order 14192. Comments are due Nov. 25, and reply comments are due Dec. 28.

What the FNPRM Proposes

The FCC proposes or seeks comment on six principal changes to its space licensing framework.

  • Operational envelopes. Applicants could request authority within broader defined envelopes and adjust operations within those envelopes without further commission permission, rather than seeking formal amendments as operations evolve.
  • Space-based experimental license. A new license type for testing, experimentation, demonstration or validation on an unprotected, noninterference basis. Under one proposed approach, licenses would have a two-year term with one renewal of up to two years. The FCC also seeks comment on applying existing Part 5 provisions that allow terms of up to five years with sufficient justification.
  • Experimental-to-commercial conversion. Holders of a space experimental license could request conversion to a regular Part 100 authorization, generally processed as a major modification application, with faster action possible for conversions that do not seek additional interference protection.
  • NGSO call sign merging. Non-geostationary orbit satellite system operators could consolidate authorized satellites under multiple call signs into a single system under one call sign. The new NGSO definition adopted in the July order applies prospectively, leaving existing licenses unchanged unless their holders request consolidation.
  • Enhanced ephemeris data sharing. The July order established ephemeris data-sharing requirements and encouraged updates within an eight-hour timeframe. The FNPRM seeks comment on requiring more frequent sharing and certifying private space situational awareness providers as compliant alternatives.
  • U.S.-based control point. The FCC tentatively concludes it should require all commission-licensed space stations to maintain a U.S.-based control point. Current rules require a 24/7 point of contact with authority and capability to cease transmissions, but that person need not control the entire satellite system.

The Cost Estimate

The FCC estimates total compliance costs for the accompanying July Report and Order at approximately $27.1 million over 2026-2030, using a 3% discount rate. These estimates concern the adopted licensing overhaul rather than the additional requirements under consideration in the FNPRM. The three main components are:

  • Familiarization: Approximately $13.2 million, based on 20 engineer hours and 40 attorney hours per space station licensee, and half that for earth station licensees.
  • Surety bond net costs: Approximately $13.4 million at a 3% discount rate, which the FCC describes as "a substantial overestimate" used as a "conservative ceiling," assuming an average of four new nongeostationary orbit operators per year beginning in 2027.
  • Safety reporting: Approximately $425,000 at a 3% discount rate.

Against those costs, the FCC estimates a producer surplus benefit of at least $42 million over the same period at a 3% discount rate, assuming U.S. satellite data services market growth accelerates by one additional week over 2026-2030.

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The Fight Over the Rule

Approximately 86 parties commented on the October 2025 notice, and some opposed changes to earth station antenna performance standards and off-axis EIRP density limits, which the commission deferred for further consideration. Commenters including SIA, Telesat, SpaceX, Amazon Leo, CTIA, SES and Verizon raised objections to proposed changes in the prior round, and the commission declined to act on those issues at that stage.

SpaceX suggested aligning earth station radiofrequency exposure rules with Part 2 requirements, and HawkEye 360 requested that adding or changing radiofrequency sensing capabilities be treated as a notification-only modification. The commission did not adopt either proposal in the July order and now seeks further comment on both. It also seeks comment on CSSMA's suggested streamlined market access pathway for ground-station-as-a-service operations.

The Bottom Line

Comments are due Nov. 25, and reply comments are due Dec. 28. The FCC also proposes closing IB Docket No. 18-313 on orbital debris mitigation, stating those issues are better addressed in the current proceeding, along with IB Docket Nos. 22-411, 18-314, and 18-86, which it says are superseded by the July order.

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