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Santiago Zalazar

Santiago Zalazar is a senior associate at Covington & Burling LLP in Washington, DC and a member of the firm’s Litigation & Investigations Group. He is one of the associate co-leads of the Latino Lawyer Affinity Group at Covington.

Santiago represents clients in complex international disputes, including representation of sovereign governments and domestic and foreign corporations from diverse industries in institutional and ad hoc arbitrations involving both common law and civil law systems under ICSID, UNCITRAL, ICC, ICDR, and AAA rules, and multi-jurisdictional federal and state litigation in the United States. He has advised clients on trade and regulatory matters, such as anti-bribery and corrupt practices, economic sanctions and national security laws, and regulation of satellites and associated frequencies by the FCC.

Mr. Zalazar maintains a robust pro bono practice, advising clients on public international law, immigration, housing, and tax matters, and he has been recognized by the District of Columbia Courts for his pro bono services.

Prior to practicing law, Mr. Zalazar worked for the Organization of American States (OAS), the Center for Strategic and International Studies (CSIS), and the Embassy of Argentina in Washington, DC, where he principally assisted in the coordination of the government relations strategy of the Congressional and International Legal Affairs Unit, for which Mr. Zalazar served as a liaison to the U.S. Congress for almost six years.

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Updated May 28, 2024.  Originally posted May 10, 2024.

The U.S. Federal Communications Commission (FCC) is set to reopen the public comment period on potential further amendments to its orbital debris mitigation rules, providing space industry stakeholders with a new opportunity to provide input on regulations with far-reaching implications.  Further illustrating the FCC’s commitment to leadership in regulating commercial space operations, stakeholders have until Thursday, June 27 to provide input on the agency’s regulation of orbital debris.  Today’s Federal Register sets this comment deadline, as well as a cutoff of Friday, July 12 for any reply comments.

The relevant action is a Public Notice issued by the FCC’s Space Bureau, which the agency created last year as part of an effort to increase its role in regulating the fast-growing space economy.  The Public Notice seeks to refresh the FCC’s record concerning proposed amendments to its orbital debris mitigation rules, which generally require that U.S. satellite operators (and non-U.S.-licensed satellite operators seeking U.S. market access) submit to the FCC satellite design and operational strategies intended to minimize the risk of orbital debris.

The FCC last sought comment on these issues in April 2020, when it expanded and refined its existing orbital debris mitigation framework.  In a corresponding move, the FCC also sought input, through a Further Notice of Proposed Rulemaking (FNPRM), on additional rule amendments and proposals related to, among other issues:

  1. How satellite operators may demonstrate that they have adequately assessed and limited the probability of accidental explosions;
  2. How the FCC should evaluate the collision risk presented by large, multi-satellite constellations;
  3. Whether the FCC should adopt a requirement that all non-geostationary orbit (NGSO) satellites planned for operation above a certain altitude maintain propulsion capabilities designated for station-keeping and collision-avoidance maneuvers;
  4. How the FCC should consider human casualty risk, particularly with regard to large, multi-satellite constellations; and
  5. Whether, as a condition of an FCC satellite license, the FCC should require satellite operators to commit to indemnifying the U.S. government for any liability from claims for damage resulting from satellite operations.

Continue Reading FCC’s Space Bureau Seeks Further Input on Regulation of Orbital Debris; Comments Due June 27