Federal Communications Commission FCC 15-167
STATEMENT OF 
COMMISSIONER MICHAEL O’RIELLY
Re:   Comprehensive Review of Licensing and Operating Rules for Satellite Services, IB Docket No. 
12-267
I commend the Chairman and the International Bureau for taking the necessary steps to update
and streamline the Commission’s satellite rules.  Fifteen years is far too long to wait for a comprehensive
review and update of any Commission regulation.  Such an undertaking should occur on a regular basis to 
ensure that our rules remain current and consistent with industry trends.
Generally, I support today’s action that should modernize our rules, reduce burdens on industry 
and more closely align the Commission’s processes with those of other administrations.  Hopefully, these 
changes will increase the likelihood that, going forward, U.S. companies will have greater incentives to 
approach the Commission to acquire satellite allotments from the International Telecommunication 
Union.
Of course, sound satellite policy also calls for the requisite counterbalance.  Facilitating the 
licensing process must not result in a multitude of filings that will never be pursued, creating spectrum 
inefficiencies.  Today’s item seems to strike an appropriate equilibrium.  At the same time, I am 
concerned whether the application surety bond is the correct approach to prevent warehousing.  Other 
countries’ administrations do not require such a bond and industry participants generally oppose it.  Not 
to mention that sufficient justification for such a bond seems lacking in the record.
Besides streamlining our filing and process requirements, this order retains the two-degree 
spacing policy with a few changes and modifies many other highly technical rules.  Two-degree spacing 
was the main focus of ex parte meetings with various interested parties.  Unfortunately, as in so many 
other proceedings, it once again became readily apparent that stakeholders had varying levels of 
knowledge about what was actually contained in the draft.  Some entities seemed to have an impressively 
thorough understanding, several had received conflicting information, and others had none at all.  What 
an amazing waste of time and effort.  This is a perfect example of why the public should have had access 
to this draft and every other at the time that they are circulated to the Commissioners.  Not only does 
fairness demand that all should be on the same playing field, but such transparency would have promoted 
further industry input, which would have been helpful to ensure that the many technical requirements and 
procedures set forth in this item work collectively.  I do not intend to let this issue go when we have a 
simple and obvious solution right in front of us.
It is my understanding that, while working on this proceeding, staff has determined there are 
other rules and processes that should be reviewed or need further thought.  They have informed me that 
additional notices and guidelines will be forthcoming shortly.  This will provide us with an opportunity to 
further streamline our rules and procedures and consider any other necessary modifications.  I thank the 
International Bureau for their hard work on this voluminous order and their efforts to come.