STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY
Re: Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and 
Related Matters, IB Docket No. 16-408, Report and Order and Further Notice of Proposed 
Rulemaking.
I am supportive of today’s order setting forth the technical rules for next-generation non-
geostationary-satellite orbit (NGSO) fixed systems.  Hopefully, our decision will provide applicants with 
the needed certainty to further explore and invest in these new constellations.  These NGSO systems bring 
the promise of high speeds and low latency, which ultimately may bring gigabit broadband to all, 
including remote areas, but several are ambitious undertakings involving hundreds and thousands of small 
satellites.  
What has become apparent is that satellite operators have designed very different orbital systems. 
This poses quite the challenge for the Commission, as the satellite industry is not in agreement on some of 
the issues decided in this item. For instance, there is real concern over how the potential for in-line 
interference should be handled. While the hope is that operators will enter into coordination agreements, 
if this does not occur, the Commission has adopted a default sharing mechanism that some entities seem 
to support, some support with some modifications, while still others articulate quite convincingly that it 
won’t work at all. I’m not so sure those internally believe it would work as planned if actually triggered.  
This scheme may need to be revisited on reconsideration or, potentially, in the future when these systems 
are more mature. Some also question whether there are sufficient launch capabilities to get all of these 
satellites into orbit in time to meet the performance benchmarks. This is also something worth 
monitoring and waivers may, or may not, be necessary in the future. 
Ultimately, we may need to see how these systems develop and how many come to fruition and, 
based on the actual systems deployed, rule tweaks may be necessary. I think we all know that twelve 
NGSO systems – and this does not include the V-band constellations – are unlikely.  For the time being,
we have done our best to provide the necessary framework and environment for investment.  I wish the 
satellite industry the best of luck and look forward to seeing this engineering feat come to reality.