FCC Releases Draft Report & Order Streamlining Satellite Licensing Processes

By Gerard J. Waldron, Corey Walker & John Bowers on July 28, 2025

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.”

Additional Earth Station Modifications Do Not Require Prior Approval. The FCC’s rules already permit certain changes to earth station licenses through a notification process that does not require prior FCC approval. For instance, currently earth station licensees can expand the number of devices with a simple notice. The R&O would expand this “notice-only” treatment to additional types of earth station modifications, including (among others):
- Changes to Earth Station Equipment. If an earth station operator seeks to use new equipment that would not (a) increase the risk of harmful interference nor (b) increase the radiation risk to humans, then no filing would be required (i.e., neither prior approval nor notice).
- Removal of Satellite “Points of Communication.” Similar to the new notice-only flexibility for adding a satellite point of communication, an earth station operator also could remove a satellite as a point of communication based on notice rather than prior approval.
- GSO Operations During Relocations. The changes would allow a Geostationary Orbit (“GSO”) satellite to continue all operations, not just telemetry, tracking and command (“TT&C”), during relocation drifts subject to certain conditions. Specifically, all such operations would have to be limited to coordinated operations and be on an unprotected, non-harmful interference basis.

All Satellite and Earth Station License Proceedings “Permit and Disclose” by Default. This change clarifies that all satellite and earth station licensing proceedings will be presumed to have “permit-but-disclose” status. As a practical matter, this means ex parte meetings are permitted and a notice will need to be filed in the relevant application docket for any meetings related to the application.

Expanded Earth Station and NGSO License Renewal Window. Currently, the window to renew an earth station license is no earlier than 90 days and no later than 30 days before the expiration date. The R&O would expand this renewal window to allow the filing of renewal applications for earth station licenses 12 months ahead of expiration. The deadline would remain 30 days prior to expiration. This renewal window would also apply to NGSO satellite licenses, where previously NGSO operators had to file for renewal no earlier than 90 days and no later than 30 days before the end of the twelfth year of the initial 15-year license term. The standardized renewal rule shifts the renewal window to the start of the final year of the NGSO term.

Special Temporary Access for Market Access Grantees. The R&O would permit non-U.S. licensed satellite operators that have been granted U.S. market access to seek special temporary access, which would enable those operators to change certain operating parameters of their satellites. The current rules generally do not provide that flexibility.

30-Day “Shot Clock” for Earth Station License Renewal. Although the FCC deferred on adopting set timelines for the processing of most satellite and earth station license applications, the R&O would set a 30-day shot clock for earth station license renewals. Provided earth station license renewals do not involve a modification, other changes to authorized operating parameters, or operations in frequencies subject to certain limitations, they would be granted automatically within 30 days of filing.

The R&O is part of the FCC’s ongoing efforts to promote innovation and competition in the space economy. In announcing the August vote on the R&O, Chairman Carr explained that “[c]learing out regulatory barriers will empower new competitors and innovations in space, particularly the kind of neutral-host infrastructure that has proven so successful in the wireless industry.”