Comment on Space NPRM FCC
Published
March 12, 2026
This week, the U.S. Chamber of Commerce filed an ex parte submission in the FCC’s Space Modernization for the 21st Century proceeding (SB Docket No. 25-306). The Chamber represents a broad cross-section of businesses across the space economy and terrestrial operations—including satellite manufacturers, launch providers, and satellite operators—and our comments reflect member input on how to modernize licensing without undermining the fundamentals that keep the spectrum environment stable and workable.
Overall, we support the Commission’s objective: an efficient, modern space and earth-station licensing system that reduces regulatory friction, speeds application processing, and improves predictability. Done right, process modernization can help promote investment and support the United States as the licensing forum of choice for space systems.
At the same time, we caution that procedural streamlining should not come at the expense of transparency, meaningful stakeholder participation, or the established rights of incumbent spectrum users—especially where changes could affect spectrum sharing with terrestrial operators (co-channel or adjacent-channel). In our view, reforms in this proceeding should remain focused on process improvements and avoid substantive changes to the balance embedded in frequency-specific rules.
We also urged targeted refinements to strengthen the FCC’s final framework—such as modernizing earth-station licensing (including nationwide, non-site-based licensing in appropriate bands), aligning more closely with ITU filing and coordination practices (including NGSO milestone updates), and preserving Part 25 technical standards while keeping the new Part 100 focused on process. We also emphasized the importance of FCC IT modernization to make any new system work in practice, and encouraged continued engagement with industry on implementation details like maneuver/ephemeris reporting, EIRP limits and coordination, and financial assurance requirements.
We appreciate the FCC’s focus on efficient, internationally aligned processes and look forward to continued collaboration as the proceeding advances.
Please reference the attached document to view the Chamber's full submission.
