Federal Communications Commission FCC 18-44
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Streamlining Licensing Procedures for 
Small Satellites 
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IB Docket No. 18-86
NOTICE OF PROPOSED RULEMAKING
Adopted:  April 17, 2018 Released:  April 17, 2018
By the Commission: Chairman Pai and Commissioners Clyburn, O’Rielly, Carr, and Rosenworcel issuing 
separate statements.
Comment Date: (45 days after date of publication in the Federal Register).
Reply Comment Date: (75 days after date of publication in the Federal Register).
TABLE OF CONTENTS
Heading Paragraph #
I. INTRODUCTION...................................................................................................................................1
II. BACKGROUND.....................................................................................................................................2
A. A New Era of Small Satellites ..........................................................................................................4
B. Current Authorization Approach for Small Satellites.....................................................................10
C. Small Satellite Frequency Use ........................................................................................................17
D. ITU Notification for Small Satellites ..............................................................................................19
III. DISCUSSION........................................................................................................................................21
A. Streamlined Process for Small Satellites ........................................................................................21
1. Characteristics of a Satellite or System Qualifying for Streamlined Processing .....................25
a. Number of Spacecraft ........................................................................................................27
b. Planned On-Orbit Lifetime ................................................................................................28
c. License Term .....................................................................................................................29
d. Maximum Spacecraft Size .................................................................................................32
e. Deployment Orbit and Maneuverability ............................................................................33
f. Operational Debris and Collision Risk ..............................................................................35
g. Trackability ........................................................................................................................38
h. Casualty Risk .....................................................................................................................39
i. Cessation of Emissions ......................................................................................................40
2. Small Satellite Application Processing ....................................................................................41
3. Application Requirements ........................................................................................................47
4. Revised Bond Requirement......................................................................................................49
5. Technical Rules ........................................................................................................................54
B. Frequency Considerations for Small Satellites ...............................................................................55
1. Scope of Frequency Use...........................................................................................................56
2. Compatibility and Sharing with Federal Users ........................................................................60
3. Small Satellite Operations as an Application of the MSS........................................................62
4. Discussion of New Small Satellite Operations in Select Bands...............................................63
Federal Communications Commission FCC 18-44
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a. 137-138 MHz and 148-150.05 MHz..................................................................................64
b. 1610.6-1613.8 MHz...........................................................................................................68
5. Use of MSS and FSS Frequency Bands for Inter-Satellite Links with Small Satellites ..........70
IV. FEES......................................................................................................................................................74
V. CONCLUSION .....................................................................................................................................78
VI. PROCEDURAL MATTERS.................................................................................................................79
VII. ORDERING CLAUSES.......................................................................................................................83
 APPENDIX A – Proposed Rules
APPENDIX B – Initial Regulatory Flexibility Analysis
I. INTRODUCTION
1. In this Notice of Proposed Rulemaking (Notice), we seek comment on proposed revisions 
to our rules to facilitate deployment of a class of satellites known colloquially as “small satellites.”  These 
types of satellites, which have relatively short duration missions, have been advancing scientific research 
and are increasingly being used for commercial endeavors such as gathering Earth observation data.  The 
proposed rules are designed to lower the regulatory burden involved in licensing small satellites and 
reduce application processing times, while offering protection for critical communication links and 
enabling efficient use of spectrum for this dynamic sector. 
II. BACKGROUND
2. The impetus for this Notice is to facilitate the authorization and operations of “small 
satellites.”  Although a wide variety of satellites are being designed and launched as “small satellites,” the 
Commission has not previously defined this category of space objects.  There are a number of ways of 
describing small satellites.  A recent International Telecommunication Union Radiocommunication (ITU-
R) Report indicated that satellites weighing less than 500 kilograms (kg) are sometimes referred to as 
small satellites.
1
  The National Aeronautics and Space Administration (NASA) has in some instances 
described small satellites as satellites having a mass of less than 180 kg.
2
  The ITU-R Report focused on 
satellites that have a mass of less than 10 kg and identified their typical mission duration as less than three 
years.
3
  Such missions have been characterized in other ITU-R documents as “short duration missions.”
4
  
Other notable typical characteristics of small satellites include operation in low-Earth orbit (LEO), as well 
as lower power as compared with traditional satellite systems.
5
  This proceeding seeks to address this 
category of  “small satellites” which we propose to define by seeking comment on a number of particular 
characteristics. 
1
 See International Telecommunication Union, Radiocommunication Sector (ITU-R), Characteristics, definitions and 
spectrum requirements of nanosatellites and picosatellites, as well as systems composed of such satellites, Report 
SA.2312 (Sept. 2014), https://www.itu.int/en/ITU-R/space/Documents/R-REP-SA.2312-2014-PDF-E.pdf (ITU-R 
Characteristics Report).  The ITU-R Report focused on a subset of satellites that have been characterized as 
“nanosatellites” and “picosatellites.”  Id. at 2.  Nanosatellites typically have a mass of 1-10 kg, and picosatellites 
typically have a mass of 0.1-1 kg.  Id. at 3.
2
 See, e.g., NASA Ames Research Center, Small Spacecraft Technology State of the Art, NASA/TP-2015-
216648/REV1 at 1 (Dec. 2015), 
https://www.nasa.gov/sites/default/files/atoms/files/small_spacecraft_technology_state_of_the_art_2015_tagged.pdf 
(NASA Small Spacecraft Technology Report) (describing small satellites as spacecraft with a mass of less than 180 
kg for purposes of the Report).
3
 ITU-R Characteristics Report at 3.
4
 ITU-R Resolution 659 (WRC-15), Studies to accommodate requirements in the space operation service for non-
geostationary satellites with short duration missions (defining “short duration mission” as typically not lasting more 
than three years).
5
 ITU-R Characteristics Report at 9. 
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3.  The Commission has authorized small satellites both as commercial operations under 
Part 25 of the Commission’s rules and as experimental operations — including scientific and research 
missions for purposes of experimentation, product development, and market trials — under Part 5 of the 
Commission’s rules.  Some amateur small satellite operations have also been authorized under Part 97 of 
the Commission’s rules.  Because of the increasingly commercial nature of small satellite missions, many 
satellites are not suitable for licensing under the Commission’s Part 5 experimental licensing process, and 
Part 5 licensees cannot obtain interference protection for radiocommunications links.  On the other hand, 
obtaining a Part 25 regular commercial authorization for an NGSO system can be challenging for some 
small satellite applicants because of the costs and timelines involved, as compared to the overall scope of 
most small satellite enterprises.  The same application and regulatory fees are currently applicable to all 
NGSO Part 25 applicants and licensees, regardless of the specific characteristics of the system.
6
  In some 
instances, these fees constitute a large percentage of the cost of the small satellite system, and could even 
exceed the total cost of a small satellite mission.  Part 25 licensees are also subject to a requirement to 
post an initial surety bond,
7
 which can be challenging for licensees planning small, low-cost systems.  
Further, under Part 25, most NGSO satellite applications are processed according to a processing round 
procedure,
8
 which can add to application review time by the Commission and regulatory complexity for 
applicants.  Given some of the challenges presented by the Commission’s licensing process to small 
satellite systems and their promise as a driver of innovation, our goal in this proceeding is to develop a 
streamlined authorization process within Part 25 that is tailored to small satellites.
A. A New Era of Small Satellites
4. Today the small satellite sector is engaged in a range of activities, from brief research-
oriented satellite missions to regularly replenishing commercial satellite constellations operating over a 
number of years.
9
  While this Notice is focused on those missions having short duration, we observe that 
there appears to have been growth in this sector across the full range of activities.  For purposes of this 
rulemaking we are not proposing to consider non-geostationary orbit (NGSO) FSS constellations that 
include numerous satellites to be “small satellites,” even if the physical size of each of those satellites 
could be considered small.
10
  We believe that the characteristics proposed below for small satellites 
applying under the streamlined process, such as an orbital lifetime of five years or less and the ability to 
share spectrum with existing and future operators in a particular frequency band, will differentiate small 
satellite systems under consideration in this Notice from typical NGSO FSS, MSS, or other systems 
6
 See Amendment of Schedule of Application Fees Set Forth in Sections 1.1102 through 1.1109 of the Commission’s 
Rules, Order, 31 FCC Rcd 7534 (July 6, 2016) (2016 Application Fees Order); Regulatory Fees Fact Sheet, What 
You Owe – International and Satellite Services Licensees for FY 2017, Public Notice, (Sept. 6, 2017), available at 
https://apps.fcc.gov/edocs_public/attachmatch/DOC-346552A1.pdf (2017 Regulatory Fees Fact Sheet).
7
 47 CFR § 25.165(a)(3).
8
 See 47 CFR § 25.157.
9
 These replenishing satellite systems consist of satellites that are replaced on a regular basis, as the service 
continues to be provided.  An example of a system in this category is Planet’s NGSO system.
10
 For example, some of the planned NGSO FSS systems consist of what could be considered “minisatellites”, with 
a typical mass between 100 kg and 500 kg.  See ITU-R Characteristics Report at 3; see, e.g., Space Exploration 
Holdings, LLC, International Bureau Filing System (IBFS) File No. SAT-LOA-20161115-00118, Attachment A, 
Technical Information to Supplement Schedule S, at 54 (stating that a SpaceX satellite will have a vehicle mass of 
386 kg).  The Commission recently updated its rules applicable to NGSO FSS systems.  See Updates to Parts 2 and 
25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters, Report and Order and 
Further Notice of Proposed Rulemaking, FCC 17-122, 32 FCC Rcd 7809 (2017) (NGSO FSS R&O).  This 
proceeding is also not tailored to address the operations of traditional NGSO satellite constellations offering mobile-
satellite service (MSS), such as those operated by Iridium LLC, Globalstar, Inc., or ORBCOMM License Corp., 
more traditional NGSO satellites offering remote sensing operations, or those in the Satellite Digital Audio Radio 
Service (SDARS), among others.  
Federal Communications Commission FCC 18-44
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requiring full-time uninterrupted availability of assigned spectrum.  We recognize that NGSO FSS 
systems may in part be responsible for some growth indicators discussed below, such as launch vehicle 
development, but to the extent possible we have sought to exclude those systems from our discussion of 
trends in this sector.  
5. For much of the history of the satellite industry, economies of scale, increased 
capabilities of launch vehicles, and rising global demand for satellite services pushed satellite 
manufacturers to focus their efforts on designing larger and more powerful satellites.
11
  In the last 15 
years, however, the miniaturization of components and the ability of small satellite developers to 
capitalize on commercial off-the-shelf equipment has enabled smaller, cheaper satellites to be built and 
launched into space.
12
  In 1999, engineers at California Polytechnic State University and Stanford 
University developed a small satellite standard known as the “CubeSat” design, with the goal to train 
students and expose them to real-world engineering practices and design.
13
  The CubeSat is a standardized 
interface consisting of an approximately 10 cm x 10 cm x 10 cm unit or “U” that can be scaled up to 
create CubeSats that are 3U (three units) or 12U (12 units) in size, for example.
14
  The standardized 
specification enables CubeSats to be fully enclosed in specially developed deployment mechanisms that 
can be added to launch vehicles as secondary payloads.
15
  The CubeSat specification has been widely 
adopted even outside the academic community, largely due to low costs and access to launch services, 
and satellites based on the standard constitute a large percentage of small satellites deployed in recent 
years.  While the advantages of small satellites have ensured their continuing use by universities and 
research institutions, it has also encouraged the growing number of CubeSat missions that are 
commercial.
16
  
6. Commercial sector involvement in all small satellites, not just CubeSats, has increased 
significantly in recent years.  Venture capital firms are investing in small satellite companies, such as 
those providing Earth imagery.
17
  According to one report, the use of small satellites for commercial 
11
 Ram S. Jakhu & Joseph N. Pelton, Small Satellites and Their Regulation, 1-2 (Springer 2014).
12
 See, e.g., John Toon, The Future is Small, Georgia Tech Research Horizons (Nov. 28, 2015), 
http://www.rh.gatech.edu/features/future-small; Euroconsult, $22 Billion Market Value for Small Satellites Over 
Next Ten Years (July 7, 2016), http://www.euroconsult-ec.com/7_July_2016; Jakhu & Pelton, supra note 11, at 21-
23.  
13
 See National Academies of Sciences, Engineering, and Medicine, Achieving Science Goals with CubeSats: 
Thinking Inside the Box, at 6, 8 (2016), https://doi.org/10.17226/23503 (National Academies CubeSat Report).  See 
also ITU-R Characteristics Report at 3 (CubeSat design developed “with the goal of easing access to space for the 
academic community”); CubeSat.org, The CubeSat Program, http://www.cubesat.org/about/ (last visited Jan. 2, 
2018). 
14
 See National Academies CubeSat Report at 6.
15
 Id. at 6, 8.
16
 See id. at 8, 55-59. 
17
 Clay Dillow, Here’s Why Small Satellites Are So Big Right Now, Fortune (Aug. 4, 2015), 
http://fortune.com/2015/08/04/small-satellites-newspace; Samantha Masunaga, Trips to Mars won’t make quick 
money, but venture capitalists are jumping on other space projects, Los Angeles Times (Oct. 27, 2016), 
http://www.latimes.com/business/la-fi-tech-vc-space-20161027-snap-20161027-story.html; Alex Knapp, The Space 
Companies Getting a Boost from Midas List Members, Forbes (April 8, 2017), 
https://www.forbes.com/sites/alexknapp/2017/04/18/the-space-companies-getting-a-boost-from-midas-list-
members/#6f0cfed21d19.
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purposes represents a shift from the practice before 2013, when the majority of small satellites were used 
for government and academic operations.
18
  
7. The total number of small satellites, including CubeSats, being deployed annually has 
increased significantly in recent years.  A report by the Satellite Industry Association (SIA) shows a 
steady increase in CubeSat deployment from 2011, when fewer than 20 CubeSats were launched, to 2015, 
when 108 CubeSats were launched.
19
  Although the SIA report notes that the number of CubeSats 
launched decreased in 2016 to 55, it attributes this decrease to launch delays.
20
  When launches are 
successful, a large number of small satellites can be deployed as part of a single mission.  In early 2017, 
for example, an Indian Space Research Organization launch vehicle deployed over 100 small satellites 
into orbit in a single launch.
21
  One forecast estimates that between 2017 and 2023, nearly 2,400 satellites 
with masses ranging between 1 and 50 kg will be launched.
22
  
8.  Small satellites are typically launched as secondary payloads and this limits the choice of 
launch time and the orbit in which they will be placed.  Currently, however, a number of launch vehicles 
under development are designed to launch small satellites as primary payloads.
23
  With the increase in 
small satellite launches and launch opportunities, the number of small satellites deployed is growing 
quickly and is predicted to continue to increase in the coming years.  
9. The United States continues to be the leader in the number of small satellites launched,
24
 
and in the last several years the Commission has licensed several commercial earth exploration satellite 
service (EESS)
25
 constellations that operate using small satellites based on the CubeSat concept.
26
  These 
18
 Elizabeth Buchen, Small Satellite Market Observations at 4 (2015), 
https://digitalcommons.usu.edu/smallsat/2015/all2015/51/  (noting that in 2014, 107 nano/microsatellites were 
launched, with the commercial operator Planet supplying 93 of the 107 launched). 
19
 Satellite Industry Association, State of the Satellite Industry Report at 22 (2017) http://www.sia.org/wp-
content/uploads/2017/07/SIA-SSIR-2017.pdf.
20
 Id.  See also 2017 Nano/Microsatellite Market Forecast, SpaceWorks at 6 (2017), 
http://www.spaceworkscommercial.com/wp-
content/uploads/2018/01/SpaceWorks_Nano_Microsatellite_Market_Forecast_2017.pdf (2017 Nano/Microsatellite 
Market Forecast).
21
 Jeff Foust, India Sets Record with Launch of 104 Satellites on a Single Rocket, SpaceNews (February 15, 2017), 
http://spacenews.com/india-sets-record-with-launch-of-104-satellites-on-a-single-rocket/. 
22
 See 2017 Nano/Microsatellite Market Forecast at 9.
23
 See, e.g., Sarah Scoles, This New Goldilocks Rocket Is Juuust Right for Small Satellites, Wired (May 25, 2017) 
https://www.wired.com/2017/05/new-goldilocks-rocket-juuust-right-small-satellites/; Rocket Lab, Rocket Lab 
Successfully Makes it to Space (2017), https://www.rocketlabusa.com/latest/rocket-lab-successfully-makes-it-to-
space-2/; Alex Knapp, Successful Launch Of Vector Rocket Is One Giant Leap For The Industry, Forbes (May 3, 
2017), https://www.forbes.com/sites/alexknapp/2017/05/03/successful-launch-of-vector-space-systems-rocket-is-
one-giant-leap-for-the-industry/. 
24
 See, e.g., National Academies CubeSat Report at 14 (showing the number of CubeSats launched by the United 
States and other countries).
25
 The EESS is a radiocommunication service between earth stations and one or more space stations, which may 
include links between space stations, in which: (1) information relating to the characteristics of the Earth and its 
natural phenomena, including data relating to the state of the environment, is obtained from active sensors or passive 
sensors on Earth satellites; (2) similar information is collected from airborne or Earth-based platforms; (3) such 
information may be distributed to earth stations in the system concerned; and (4) platform interrogation may be 
included.  This service may include feeder links necessary for its operation. 47 CFR § 2.1; ITU R.R. 1.51.  
26
 Operators in this category include the NGSO constellations of Planet, Spire Global, Inc. (Spire), and Terra Bella 
Technologies, Inc. (Terra Bella) (formerly known as Skybox Imaging, Inc.).  See, e.g., International Bureau Filing 
(continued….)
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constellations, consisting of a large number of rapidly-replenishing satellites, have been licensed under 
Part 25 of the Commission’s rules.  The Commission has also fielded an increasing number of 
applications from small satellite proponents seeking authorization under the experimental licensing 
process under Part 5 of the Commission’s rules.
27
  Particularly since 2013, the Commission has seen a 
marked increase in the number of unique small satellite systems seeking to be licensed.  Many of these 
applications are still from universities or other research-oriented organizations with intended short 
duration missions, but a growing number of others are applications from commercial entities that may 
plan to transition to licensing under Part 25 of the Commission’s rules after completing a technology 
testing and demonstration phase.
28
  
B. Current Authorization Approach for Small Satellites
10. The Commission currently authorizes small satellites in three ways: (1) as commercial 
satellite operations under Part 25 of the Commission’s rules,
29
 (2) as experimental operations under Part 5 
of the Commission’s rules,
30
 and (3) as amateur service satellite operations under Part 97 of the 
Commission’s rules.
31
  
11. Authorization is required prior to launch.
32
  The ITU Radio Regulations require that no 
transmitting station may be established or operated by a private person or by any enterprise without a 
license by or on behalf of the government of the country to which the station in question is subject.
33
  The 
Communications Act of 1934, as amended (the Act) requires the issuance of a license for communications 
to and from the United States or from any U.S. satellite,
34
 and provides the Commission with authority to 
take actions to implement the ITU Radio Regulations.
35
  Commission licensing is also an important aspect 
(Continued from previous page)  
System (IBFS) File Nos. SAT-MOD-20150802-00053 (Planet), SAT-LOA-20151123-00078 (Spire), SAT-MOD-
20150408-00019 (Terra Bella).
27
 Proponents of more than 200 unique systems consisting of one or more satellites have applied for a license 
through the experimental licensing process since 2009.  In 2013, recognizing the increasing number and variety of 
organizations seeking to participate in the launching of satellites, the Commission issued a public notice with 
guidance on obtaining licenses for small satellites, including small satellites seeking experimental licenses.  
Guidance on Obtaining Licenses for Small Satellites, Public Notice, DA 13-445, 28 FCC Rcd 2555, 2555 (March 
15, 2013) (Small Satellite Licensing Guidance).
28
 Planet and Spire are two examples of small satellite ventures that have been transitioned from the experimental 
testing phase to commercial operations.  See, e.g., Planet Labs Inc., ELS File No. 0548-EX-PL-2012 (granted Jan. 
31, 2013), IBFS File No. SAT-LOA-20130626-00087 (granted Dec. 3, 2013); Spire Global, Inc., ELS File No. 
0213-EX-PL-2014 (granted April 25, 2014), IBFS File No. SAT-LOA-20151123-00078 (granted May 18, 2017).
29
 See 47 CFR Part 25, Satellite Communications.
30
 See 47 CFR Part 5, Experimental Radio Service.
31
 See 47 CFR Part 97, Amateur Radio Service.
32
 This would not include an operator of a satellite authorized by an administration other than the United States, that 
is seeking to access to the U.S. market under Part 25 of the Commission’s rules to communicate with earth stations 
in the United States.  See 47 CFR § 25.137.  In that instance, an applicant may file a request to access to the United 
States market after the satellite or satellites are launched and operational.  See 47 CFR § 25.137(c).  In addition, 
satellite operators authorized by an administration other than the United States do not require a Commission 
authorization if earth station operations are exclusively outside the United States. 
33
 ITU Radio Regulations (R.R.), No. 18.1 (2015).
34
 47 U.S.C. § 301(d), (f).  
35
 47 U.S.C. § 303(r).
Federal Communications Commission FCC 18-44
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of ensuring that the United States satisfies the treaty obligation for authorization and continuing 
supervision of the space activities of non-governmental entities.
36
  
12. Part 25 Satellite Licensing.  The Commission’s Part 25 rules are the primary vehicle for 
satellite authorization and are used to license a wide range of satellite operations, including commercial 
communication and remote sensing satellites.  Applicants must meet the legal, technical, and other 
qualifications of Part 25, and identify the public interest considerations in support of grant.
37
  The 
Commission licenses most NGSO satellites through a processing round procedure, whereby a lead 
application is placed on public notice, and the public notice establishes a cut-off date for competing 
NGSO satellite systems entering into the processing round.
38
  The processing round procedure is intended 
to facilitate the potential for competitive market entry, under the rationale that NGSO systems generally 
cannot operate using the same spectrum without causing unacceptable interference to each other.
39
  
13. The Commission has licensed under the Part 25 rules several NGSO constellations 
utilizing smaller satellites based on the CubeSat concept.
40
  While some waivers have been requested in 
these applications,
41
 many of the Commission’s existing NGSO rules have been readily applicable to 
these types of systems.  However, the types of NGSO constellations that have been licensed under Part 25 
that use smaller-sized satellites are often large commercial constellations, in some cases envisioned to 
include hundreds of small satellites deployed more or less continuously over an extended period.
42
  The 
same procedures may not be suitable for an operator launching fewer small satellites with an intended 
short duration mission, because of fees and those costs associated with posting a surety bond, as well as 
the extended timelines associated with a Commission processing round.  A processing round may not be 
necessary for systems that do not require constant spectrum availability, since sharing may be more easily 
attainable with future systems seeking to use the same spectrum.  Some of these factors specific to the 
application process in Part 25 may explain why the number of Part 25 licenses has not increased 
appreciably in recent years while the number of individual small satellites licensed by the Commission, 
particularly through experimental licenses, has increased.
43
  Additionally, some applicants have filed for 
licensing under the experimental licensing process and then later transitioned to Part 25 commercial 
operations, rather than initially filing for a Part 25 license.  These factors suggest that some applicants 
could benefit from an authorization process for regular (rather than experimental) operations that utilizes 
36
 Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the 
Moon and Other Celestial Bodies, art. 6, adopted Oct. 10, 1967, 18 U.S.T. 2410, 610 U.N.T.S. 205 (Outer Space 
Treaty).
37
 See, e.g., 47 CFR § 25.114(d)(6).
38
 47 CFR § 25.157.
39
 See Amendment of the Commission’s Space Station Licensing Rules and Policies, First Report and Order and 
Further Notice of Proposed Rulemaking, 18 FCC Rcd 10760, 10773, paras. 21-22 (2003) (Space Station Licensing 
Reform Order).  
40
 See, e.g., IBFS File Nos. SAT-MOD-20150802-00053 (Planet modification application to operate up to 600 
technically identical NGSO EESS satellites, granted in part and deferred in part, June 15, 2016), SAT-LOA-
20151123-00078 (Spire application to operate up to 175 technically identical NGSO satellites, granted in part and 
deferred in part, June 16, 2016), SAT-MOD-20150408-00019 (Terra Bella modification application to operate up to 
13 NGSO EESS satellites, granted in part and deferred in part, June 6, 2016).  
41
 For example, applicants have requested waiver of the modified processing round requirements in Section 25.156 
and 25.157 of the Commission’s rules, discussed infra section III.A.2.  See 47 CFR §§ 25.156, 25.157.
42
 See, e.g., IBFS File Nos. SAT-MOD-20150802-00053 (Planet modification application to operate up to 600 
technically identical NGSO EESS satellites).
43
 As noted supra, between 2009 and 2018, proponents of more than 200 unique systems consisting of one or more 
satellites have applied for an experimental license.  Of these proposed systems, approximately 120 have been 
licensed.
Federal Communications Commission FCC 18-44
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a process different from the Commission’s existing Part 25 NGSO authorization process.  Accordingly, in 
Section III of this Notice, we propose a new approach to licensing small satellites that differs from our 
existing Part 25 process.  If adopted, this new approach could enable small satellite operators to obtain 
licenses for regular operation under a set of rules to be included in Part 25, but through a process better 
suited to the shorter duration of small satellite operations.
44
14. Experimental Licensing.  Experimental operations, including experimental satellite 
operations, are scientific and research missions for the purposes of experimentation, product 
development, and market trials.
45
  Section 5.3 of the Commission’s rules specifies the scope of permitted 
operations to include, among other activities, technical demonstrations of equipment or techniques, 
experimentation under contractual agreement with the United States Government, and communications 
essential to a research project.
46
  Unlike Part 25 licenses, which are typically valid for 15 years, 
experimental licenses are granted for either two or five years,
47
 and experimental Special Temporary 
Authorizations are valid for a six-month period from the date of grant and are renewable.
48
  All 
experimental licenses are granted on a non-interference basis.
49
  Accordingly, an experimental license is 
more limited than a Part 25 authorization and cannot serve as the regulatory vehicle for regular 
commercial operations using the requested frequencies.  An applicant for an experimental license should 
be the party that ultimately controls decisions about the satellite’s mission objectives, design, 
construction, deployment, and operations of the satellite once in orbit.
50
  In many cases experimental 
license applicants are not limited to universities or research institutions, but also include commercial 
ventures seeking to test equipment for developmental purposes.  All non-Federal
51
 applicants for 
experimental licenses must submit license applications through the Commission’s Office of Engineering 
and Technology (OET) Experimental Licensing System (ELS), including technical information associated 
with proposed operations.
52
  The Commission’s rules also require that applicants for an experimental 
(Continued from previous page)  
44
 See infra Section III.A.
45
 47 CFR § 5.1(b).
46
 47 CFR § 5.3(a), (d), (e).  The Commission’s rules also define an “experimental station” as “[a] station utilizing 
radio waves in experiments with a view to the development of science or technique.”  47 CFR § 5.5. 
47
 47 CFR § 5.71(a).
48
 47 CFR §§ 5.54(a)(2), 5.61(a)(1).
49
 47 CFR § 5.84 (“Operation of an experimental radio station is permitted only on the condition that harmful 
interference is not caused to any station operating in accordance with the Table of Frequency Allocation . . . .”).
50
 Small Satellite Licensing Guidance, 28 FCC Rcd at 2557.
51
 With respect to Federal operations, the National Telecommunications and Information Administration Manual of 
Regulations and Procedures for Federal Radio Frequency Management (NTIA Manual) provides relevant guidelines, 
including guidelines concerning control of such operations.  See NTIA Manual at section 8.2.17 (May 2013 ed., with 
Sept. 2015 rev.), available at http://www.ntia.doc.gov/osmhome/redbook/redbook.html.  In some instances, small 
satellite proponents that have taken part in a Federal agency program or have been involved with a Federal agency in 
some capacity may still be considered non-Federal for purposes of the satellite authorization.  See id.  If a station is 
not a Federal station, the small satellite applicant is required to follow the Commission’s licensing procedures.
52
 OET Experimental Licensing System, https://apps.fcc.gov/oetcf/els/index.cfm.  The required technical 
information includes the following: frequency, power, emission characteristics, latitude and longitude coordinates of 
the launch site or test operations; proposed launch schedule including launch date, requested grant date and any 
other critical dates relevant to the licenses; an overview of the proposed testing; a 24 hour contact for interference 
issues; a description of the anticipated orbital parameters or range of orbital parameters (altitude, inclination) in 
which the satellite will operate; and a list of any earth stations with which the satellite will communicate.  See 47 
CFR § 5.59.  If the applicant is also requesting a license to operate an earth station, it should provide the frequency, 
power, emission characteristics, and latitude and longitude information for the earth station as part of its application. 
Id.  If the applicant is planning to communicate with an earth station licensed to another entity, or operate outside 
(continued….)
Federal Communications Commission FCC 18-44
9
authorization involving a new satellite or satellite system submit a description of the design and 
operational strategies that will be used to mitigate orbital debris.
53
  
15. A satellite licensed under the Commission’s rules for experimental operations is 
distinguishable from an “experimental station” as defined in the ITU Radio Regulations.  Section 5.3 of 
the Commission’s rules lists a number of operations that may be considered for experimental licensing,
54
 
but the ITU definition is limited to a “station utilizing radio waves in experiments with a view to the 
development of science or technology.”
55
  The ITU has clarified that experimental stations, as defined by 
the ITU Radio Regulations, are meant to be used for experiments using radio waves, not for 
communicating the results of experiments using radio waves.
56
  Consequently, the ITU definition is more 
limiting than the definition of experimental operations in the Commission’s rules, and most experimental 
licenses issued by the Commission are not associated with experimental stations within the meaning of 
the ITU Radio Regulations.  
16. Amateur Satellites.  The amateur-satellite service, as a subset of the amateur service, is 
reserved for communications made for the purpose of self-training, intercommunication between amateur 
stations, or technical investigations carried out by amateurs.
57
  Rules regulating the operations of the 
amateur radio service are contained within Part 97 of the Commission’s rules.
58
  Section 97.113(a)(3) of 
the Commission’s rules, 47 CFR § 97.113(a)(3), prohibits “communications in which the station licensee 
or control operator has a pecuniary interest, including communications on behalf of an employer.”
59
  Such 
restrictions on operations in the amateur service are generally consistent with the ITU Radio Regulations 
and the domestic and international understanding of the purpose of the amateur service.
60
  Because the 
type of operations that qualify as amateur are narrowly defined, an amateur satellite authorization will not 
be appropriate for many small satellite operations.  In seeking Commission approval of amateur-satellite 
operations,
61
 the amateur-satellite control operator must submit a pre-launch notification to the 
Commission, specifically to the International Bureau, not later than 30 days after the date of launch 
vehicle determination, but no later than 90 days before integration of the satellite into the launch vehicle.
62
  
Applicants must submit to the Commission a draft “Appendix 4” notification for submission to the ITU;
63
 
early coordination with the International Amateur Radio Union (IARU) is also strongly encouraged, and 
must be completed and documented by submitting a letter from the IARU before materials will be 
the United States, its territories and possessions, then the technical parameters should be included in an exhibit to the 
application for reference purposes only.
53
 47 CFR § 5.64(b).
54
 See 47 CFR § 5.3.
55
 ITU R.R. No. 1.98.
56
 Rep. ITU-R SA.2438-0, at 9.
57
 See 47 CFR § 97.3(a)(2)-(4).
58
 See generally 47 CFR Part 97.
59
 47 CFR § 97.113(a)(3).
60
 ITU-R, Current practice and procedures for notifying space networks currently applicable to nanosatellites and 
picosatellites, Report SA.2348-0 at 8 (2015), https://www.itu.int/en/ITU-R/space/Documents/R-REP-SA.2348-
2015-PDF-E.pdf (ITU-R Notifying Space Networks Report); ITU R.R. No. 1.56.
61
 See 47 CFR §§ 97.103, 97.105.  For more information about how to obtain an amateur operator license, see: 
http://wireless.fcc.gov/services/index.htm?job=service+home&id=amateur. 
62
 47 CFR § 97.207(g).
63
 47 CFR § 97.207(g)(1).  The rule states that the pre-space notification must specify, among other things, the 
information required by Appendix 4 and Resolution No. 642 of the ITU Radio Regulations.  Id.; see ITU R.R. 
Appendix 4; ITU R.R. Resolution 642.  See also discussion infra Section II.D.  
Federal Communications Commission FCC 18-44
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submitted to the ITU.
64
  The notification to the Commission must also include a description of the design 
and operational strategies that will be used to mitigate orbital debris.
65
  Commission staff may also 
request a document describing the mission of the satellite, in order to facilitate review and verify 
eligibility for operations in the amateur service.  These documents are evaluated and, if they meet ITU 
requirements and raise no issues as to whether operations are in the public interest, the ITU filing is 
transmitted to the ITU and the orbital debris mitigation plan and any mission description are included in 
the Commission’s Universal Licensing System (ULS) file for the amateur control operator for the 
satellite.  Once materials are submitted to the ITU and placed in the ULS, the satellite is considered 
“documented” under the Commission’s rules and is authorized to operate as an amateur station.
66
 
C. Small Satellite Frequency Use
17. To date, the majority of non-governmental small satellite operations in the United States 
have been authorized through the experimental process under Part 5 of the Commission’s rules on a non-
interference, unprotected basis and with limited license terms.
67
  Non-interference, unprotected operations 
may be acceptable for some satellite operations, but for other types of operations, and particularly for 
satellite mission critical functions such as telemetry, tracking, and command (TT&C), it can be important 
that satellite links have some level of interference protection.  
18. A variety of frequency bands have been used for, or requested for use by, the types of 
operations frequently thought of as “small satellite” operations,
68
 both on a conforming and non-
conforming basis with respect to the allocations in the United States Table of Frequency Allocations (U.S. 
Table).  Frequency bands sought for use by small satellite operators for downlinks or uplinks
69
 have 
included: 137-138 MHz, 144-146 MHz, 148-150.05 MHz, 399.9-400.05 MHz, 401-403 MHz, 435-438 
MHz, 449.75-450.25 MHz, 460-470 MHz, 902-928 MHz, 2020-2025 MHz, 2025-2110 MHz, 2390-2400 
MHz, 2400-2450 MHz, 5830-5850 MHz, 8025-8400 MHz, and 25.5-27 GHz.  The majority of these 
bands have been authorized by the Commission for one or more small satellite(s) or systems, either on an 
experimental basis under Part 5 or under Part 25 of the Commission’s rules.  These authorizations have 
generally been for short duration missions and episodic uses, such that actual use of any of these bands by 
small satellites in any given area has been limited to a relatively small percentage of time.  In some 
instances, use of these frequency bands has been subject to coordination with Federal users through the 
U.S. Department of Commerce’s National Telecommunications and Information Administration (NTIA) 
inter-agency coordination process.
70
  
64
 Small Satellite Licensing Guidance, 28 FCC Rcd at 2557.  “The IARU will only coordinate a non-amateur 
satellite if an administration directs in writing that it be operated in an amateur-satellite band under an experimental 
or other non-amateur license.”  IARU, “IARU Aligns Satellite Coordination Guidelines with ITU WRC-15 
Decisions,” June 30, 2017, http://www.iaru.org/news--events/iaru-aligns-satellite-coordination-guidelines-with-itu-
wrc-15-decisions.  
65
 47 CFR § 97.207(g)(1).
66
 See 47 CFR § 97.5(a)(3).  There is no formal grant document.  In response to a need for amateur satellite operators 
to provide proof to launch providers that operations are duly authorized, staff have begun to provide the space 
station licensee an email indicating that the satellite is “documented.”  This email is also entered into the FCC ULS 
file of the licensee.
67
 See 47 CFR §§ 5.71(a), 5.84.
68
 As noted supra, we do not consider large NGSO constellations providing FSS to be “small satellites” for purposes 
of this Notice.
69
 As discussed in more detail infra, small satellite operators have also sought to communicate via inter-satellite 
links with the Globalstar and Iridium systems in bands allocated to the MSS.
70
 See infra Section III.B.2.
Federal Communications Commission FCC 18-44
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D. ITU Notification for Small Satellites
71
19. In addition to the Commission authorization process for small satellites, any frequency 
assignments of a transmitting station and to its associated receiving earth stations must be notified to the 
ITU Radiocommunication Bureau (BR)
72
 if the station is: (1) capable of causing harmful interference; (2) 
used for international radiocommunication; (3) subject to coordination procedure of Article 9 of the ITU 
Radio Regulations; (4) seeking to obtain international recognition; or (5) is a non-conforming assignment 
seeking to be recorded into the Master International Frequency Register (MIFR) for information purposes 
only.
73
  In general, small satellites, including satellites using frequencies in the amateur-satellite service 
and those authorized through the Commission’s experimental licensing process, are not exempt from the 
ITU notification process.
74
  The specific procedures for notification vary based on frequency band, 
depending on whether the frequency band is subject to coordination procedures under Article 9, Section 
II, but generally involve the submissions of technical characteristics as specified in Appendix 4 of the 
ITU Radio Regulations.  For assignments not subject to Article 9, Section II procedures, the notifying 
administration
75
 for the small satellite operations is required to send to the BR the Appendix 4 information 
in the form of an advance publication information (API).
76
  This includes information such as the 
frequency range and orbital parameters of the station, and may often encompass broader frequency ranges 
and orbital parameters than those with which the satellite will ultimately operate.
77
  Next, the BR 
publishes the relevant API/A special section in a BR International Frequency Information Circular (IFIC) 
for space services.
78
  If any administration believes that the assignment has the potential to affect 
assignments under its responsibility, it has the right to comment within four months of publication of the 
71
 Although the focus of this section is on the ITU process for small satellites, other international legal obligations, 
such as registration with the United Nations, apply to small satellites as well.  For additional guidance on these 
obligations, the United Nations Office for Outer Space Affairs released an informational document addressing the 
international legal regime relating to space activities and space objects.  See generally United Nations, Committee 
on the Peaceful Uses of Outer Space, “Guidance on Space Object Registration and Frequency Management for 
Small and Very Small Satellites,” April 2015, http://www.unoosa.org/documents/pdf/psa/bsti/2015_Handout-on-
Small-SatellitesE.pdf (UNOOSA Small Satellite Guidance).
72
 The BR is the executive arm of the Radiocommunication Sector of the ITU.  Its responsibilities include recording 
and registering frequency assignments and orbital characteristics of space services, and maintaining the Master 
International Frequency Register (MIFR).  See http://www.itu.int/net/ITU-
R/index.asp?category=information&rlink=br&lang=en. 
73
 BR-SSD e-Learning Center, Frequency Registration for Small Satellite Missions, at 5, available at 
http://www.itu.int/en/ITU-R/space/elearning/presentations/ITU_SSD_030.pdf; see ITU R.R. No. 11.2.
74
 ITU-R Notifying Space Networks Report at 7. We note, however, that frequency assignments for stations in the 
amateur service and earth stations in the amateur-satellite service are not required to be notified to the BR under 
Article 11 of the Radio Regulations.  ITU R.R. No. 11.14.  See also UNOOSA Small Satellite Guidance at 11-17.
75
 Filings must be made through a country’s administration to the BR, not directly by the satellite operator.  The BR 
cannot accept satellite network filings directly from universities, for example.  See ITU-R Notifying Space Networks 
Report at 5.
76
 The recent 2015 ITU World Radiocommunication Conference (WRC-15) decided to eliminate the requirement for 
API submissions for frequency assignments of satellite systems subject to coordination under Article 9, Section II of 
the ITU Radio Regulations.  See WRC-15 Final Acts, Resolution COM5/3 (WRC-15), available at 
http://www.itu.int/pub/R-ACT-WRC.12-2015/en.  Many small satellites and satellite systems, however, are not 
subject to the coordination procedure of Article 9, Section II of the ITU Radio Regulations, and so the API 
requirement will continue to apply.  See ITU R.R. Art. 9, §§ IA, II.
77
 See ITU-R Notifying Space Networks Report at 11, 12.
78
 See id. at 3.
Federal Communications Commission FCC 18-44
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proposed assignment.
79
  The administration that filed the API may also submit the required notification 
data to the BR at the same time, but it will be considered received by the BR no earlier than six months 
from the date of publication of the API/A.  The notification information includes the specific relevant 
information listed in Appendix 4, such as exact frequency assignments and antenna diagrams.
80
  The BR 
will then publish this information in the Part I-S publication of the BR IFIC.
81
  This constitutes an 
acknowledgement of receipt.
82
  Finally, when the examination leads to a favorable finding, the BR will 
publish the result of its technical and regulatory examinations and findings in a Part II-S publication of 
the BR IFIC, which results in international recognition and recording of the satellite’s frequency 
assignments in the MIFR.
83
  We also note that for small satellite systems seeking frequency assignments 
in bands subject to the coordination procedures in Article 9, Section II of the Radio Regulations, the 
procedures are somewhat different, involving submission of Appendix 4 information in the form of a 
coordination request (CR/C) and a formal examination by the BR for identifying potentially affected 
administrations, but also involving publication.
84
  
20. In some instances, the Commission has submitted filings to the ITU on behalf of small 
satellite applicants whose operations conform with an existing frequency allocation in the International 
Table of Frequency Allocations (International Table).
85
  In other instances, the Commission has 
authorized small satellite operations that are non-conforming to the ITU Radio Regulations, under ITU 
R.R. No. 4.4, subject to the condition that the operations shall not cause harmful interference to, and shall 
not claim protection from harmful interference caused by, a station operating in accordance with the ITU 
Radio Regulations.
86
  In both cases applicants are subject to the cost recovery provisions of section 25.111 
of the Commission’s rules.
87
79
 Id.; ITU R.R. No. 9.3.  Comments will be published by the BR in API/B special sections, and “[t]hereafter, both 
administrations shall endeavor to cooperate in joint efforts to resolve any difficulties, with the assistance of the BR if 
so requested by either of the parties, and shall exchange any additional relevant information that may be available.”  
ITU-R Notifying Space Networks Report at 3.
80
 See ITU R.R. Appendix 4.
81
 International Telecommunication Union Radio Communication Bureau, “ITU BR Registration Tutorial for the 
potential amateur satellite builders”, at 2, available at http://www.itu.int/en/ITU-R/space/AmateurDoc/ARS-
tutorial.pdf.  The BR IFIC Space Services is a service publication published every two weeks by the BR, in 
accordance with Nos. 20.1-20.6 and No. 20.15 of the Radio Regulations, containing information on the frequency 
assignments to space stations, Earth stations or radio astronomy stations submitted by administrations to the BR for 
recording in the MIFR.  See http://www.itu.int/pub/R-SP-LN.IS/en
82
 Id.
83
 Id.
84
 See, e.g., ITU R.R. No. 9.21.
85
 The International Table is subdivided into the Region 1 Table, the Region 2 Table, and the Region 3 Table.  For 
the allocation of frequencies, the ITU has divided the world into three Regions.  The United States and most of its 
insular areas are in ITU Region 2, which is generally North America and South America.  The International Table is 
included in the Commission’s rules for informational purposes only.  See 47 CFR §§ 2.104(a), (b); 2.105(a), nn.2, 3; 
2.106, International Footnotes, 2.106, footnote 5.337.  See 47 CFR § 2.104(b) for the ITU’s official definitions and 
map of the Regions.
86
 ITU R.R. No. 4.4.
87
 See 47 CFR § 25.111.  For more information on the ITU’s cost recovery policy, see Radiocommunication Bureau 
Circular Letter CR/245 (Oct. 2005), available at https://www.itu.int/md/R00-CR-CIR-0245/en.
Federal Communications Commission FCC 18-44
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III. DISCUSSION
A. Streamlined Process for Small Satellites 
21. The Commission has found that many small satellites are launched not as part of large 
constellations, but as part of small-scale operations consisting of a single satellite or only a few satellites. 
As noted, existing Part 25 rules governing NGSO-like
88
 systems are not necessarily tailored to address 
such small-scale operations and may present challenges for small satellite applicants and licensees.  We 
propose to establish a set of streamlined application and processing rules for commercial NGSO small 
satellites meeting certain criteria.
89
  As described below, it appears that satellites with the characteristics 
outlined in this Notice could be authorized on a more streamlined basis, both from a radiofrequency (RF) 
interference and orbital debris mitigation perspective, than satellites that we have typically licensed under 
the existing Part 25 rules.  Accordingly, we propose an approach for authorizing this new category of 
satellites that we believe will make the process more accessible, decrease processing time for 
applications, limit regulatory burdens borne by applicants, and offer protection for critical communication 
links, while promoting orbital debris mitigation and efficient use of spectrum.  Our objective is to develop 
an alternative arrangement for authorizing small satellites that is more efficient for both applicants and the 
Commission and that better reflects the unique nature of small satellite deployment than the existing 
authorization regimes. 
22. A primary goal of this proceeding is to better tailor the Commission’s regulatory process 
to small satellites.
90
  Currently, an application for an NGSO satellite system under Part 25 of the 
Commission’s rules requires the applicant to submit an FCC Form 312, Main Form and Schedule S, along 
with exhibits as described in section 25.114 of the Commission’s rules.
91
  NGSO systems are also subject 
to frequency-band and service-specific requirements.
92
  NGSO satellite applications are processed 
according to a processing round procedure.
93
  NGSO satellites that complete the processing round 
procedure are subject to certain milestones for completing system deployment, and a bond requirement,
94
 
as well as operational requirements that may be frequency-band or service-specific.  Under the proposed 
streamlined small satellite process, applicants would not be subject to processing round procedures, 
although certain other requirements would continue to apply, as described below.  Ideally, this new 
process would decrease the time spent by some NGSO applicants in submitting applications, as well as 
Commission staff time in processing applications, commensurate with the short mission lifetimes of many 
small satellites.  While this proposed process would still include several of the requirements in section 
25.114 of the Commission’s rules,
95
 we envision that the small satellite process will be set forth in its own 
88
 “NGSO-like” is term used in the Commission’s rules to describe systems which are either (1) NGSO satellite 
systems or (2) GSO mobile satellite service (MSS) satellite systems that communicate with earth stations using non-
directional antennas.  See 47 CFR § 25.157(a).
89
 As an example of another jurisdiction considering processes specific to small satellites, we note that the United 
Kingdom is considering a new process for CubeSat authorizations.  UK Space Agency, Draft Cubesat regulation 
recommendations, https://www.gov.uk/guidance/apply-for-a-license-under-the-outer-space-act-1986, (2015).  
90
 See National Academies CubeSat Report at 6-9 (characterizing the Commission’s “regular” satellite process as 
time-consuming and potentially expensive).
91
 See 47 CFR § 25.114.  This includes information regarding the applicant’s orbital debris mitigation plan.  47 CFR 
§ 25.114(d)(14).
92
 See, e.g., 47 CFR § 25.145 (licensing provisions for FSS satellites in the 20/30 GHz bands); 47 CFR § 25.146 
(licensing and operating rules for NGSO FSS in the 10.7-14.5 GHz bands).
93
 See 47 CFR § 25.157; Space Station Licensing Reform Order, 18 FCC Rcd at 10782-83, para. 48.  For further 
discussion, see infra Section III.A.2.
94
 See 47 CFR §§ 25.164, 25.165.
95
 47 CFR § 25.114.
Federal Communications Commission FCC 18-44
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section of Part 25 to enable small satellite applicants seeking to use this process to clearly understand the 
applicable procedures and technical requirements.  
23. Under our existing rules, entities may file a petition for a declaratory ruling to access the 
U.S. market using a non-U.S.-licensed space station.
96
  Although we at some points use the term “license” 
in this Notice, we anticipate that the same basic processes for obtaining authorization for small satellite 
operations will also be available to proponents of foreign-licensed satellites seeking U.S. market access 
via declaratory ruling.
97
  Accordingly, we do not propose rule changes that would limit the streamlined 
process to applicants seeking a U.S. license.  We seek comment on this approach.  
24. In the following part of the Discussion, we break down our proposals for streamlined 
small satellite licensing process into five subsections.  First, we propose a list of eligibility criteria for 
applying for a Part 25 license under the streamlined process.  Second, we propose an approach for 
processing these applications.  Third, we propose procedural requirements applicants would need to meet.  
Fourth, we outline proposed revisions to the bond requirement for the new process, and fifth, we seek 
comment on technical rules.    
1. Characteristics of a Satellite or System Qualifying for Streamlined 
Processing
25. We propose a series of criteria that would define the types of operations able to qualify 
for the small satellite process.  These criteria are consistent with the goals of enabling faster review of 
applications by the Commission in order to facilitate the deployment and operation of small satellites that 
can advance research missions and support services such as the provision of Earth observation data.  
Under these criteria, many satellites that are currently licensed through the experimental licensing process 
under Part 5 of the Commission’s rules would likely qualify as small satellites and therefore could be 
subject to the Part 25 streamlined process proposals.  
26. We also seek comment on whether there are other criteria not considered below that 
should be met by satellites applying under this streamlined process.  Many proposals in this Notice rely 
on the Commission’s current understanding of the characteristics and scope of operations that generally 
define small satellites; for example, that a small satellite is typically designed to serve its purpose within a 
limited, relatively short period of time, and that these satellites have more limited frequency use 
characteristics than more traditional operations licensed under Part 25, including use of narrower 
bandwidths and ability to share and not preclude other operations in a particular frequency band.
98
  Are 
these assumptions about the nature of small satellites—and any others reflected in this Notice—accurate?  
Are there any other defining traits of small satellites that we may have overlooked and should be taken 
into account as we define eligibility for the proposed streamlined process?
a. Number of Spacecraft
27. We propose to limit the number of spacecraft that can be deployed under a Part 25 small 
satellite license.  We propose to license no more than ten satellites under a single small satellite license 
and seek comment on this approach.  This is generally consistent with our experience authorizing small 
satellites.  We anticipate that many small satellite applicants intend only to launch one or a few satellites 
in total, and this proposal would enable those applicants to proceed in a streamlined manner.  We seek 
comment on this approach and on whether we should consider other factors in determining the number of 
total satellites that may be specified in any single license under the streamlined process.  We note that our 
proposed process is intended for a limited group of applicants whose operations are small enough in scope 
that it would not serve the public interest to apply certain of our standard Part 25 procedures.  We seek 
96
 See 47 CFR § 25.137.  
97
 See 47 CFR § 25.137(d).
98
 See also infra Section III.B.1 for further discussion on frequency use characteristics.
Federal Communications Commission FCC 18-44
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comment on what rules would be necessary to facilitate that goal, including whether it is necessary to 
adopt limits on the number of applications that can be filed under the proposed streamlined process by an 
individual small satellite operator or its affiliates. 
b. Planned On-Orbit Lifetime
28. For an applicant seeking a license under the streamlined small satellite process, we 
propose that the applicant must certify that the total on-orbit lifetime is planned to be five years or less, 
including the time it takes for the satellite(s) to deorbit.  The ITU has found that for nanosatellites, such as 
CubeSats, the typical operational lifetime is between one and three years, although operational lifetimes 
of five, six, or even ten years are possible for some small satellites.  The ITU also recently identified three 
years to be typically the upper limit for what it considers to be “short duration missions.”
99
  Factoring in 
time for the satellites to deorbit,
100
 and that there may be satellites launched at different times under a 
license, we seek comment on whether five years is an appropriate total on-orbit lifetime for small 
satellites that would be eligible for the streamlined process.  The five-year planned lifetime corresponds to 
satellite orbits at relatively low altitudes, consistent with other proposals in this Notice.  For example, all 
satellites lacking propulsion that are deployed at or below an altitude of 400 km will naturally de-orbit by 
atmospheric re-entry within five years.
101
  Should a small satellite that is not designed with a sufficiently 
short orbital lifespan to result in atmospheric re-entry within five years nevertheless be eligible if it has a 
capability to maneuver to a lower orbit that would ensure re-entry within five years?  Applicants seeking 
to operate a small satellite for longer than five years would not be eligible for the streamlined process and 
could seek a license or market access grant under our existing Part 25 NGSO procedures, which provide 
for longer license terms.
102
  We seek comment on this proposal and any other factors to consider in 
identifying eligible satellites based on orbital lifetime.
c. License Term
29. We propose that the license term for these satellites be five years and that the license term 
for the satellites covered by each small satellite license would begin once one satellite has been placed 
into its authorized orbit.  We anticipate that most operators would launch and operate all satellites in these 
small constellations within a short period of time, therefore it would be appropriate to begin the license 
term once the first satellite has been placed into its authorized orbit.  We seek comment on this proposed 
five-year license term and whether there are other approaches that we should consider in determining 
what constitutes an appropriate license term, such as limiting license terms to be proportional to the 
expected satellite operational lifetime.  We also ask alternatively whether the license term should begin at 
the time of grant, given the typically shorter timeline from satellite development to launch for small 
satellites.
30. License Extensions and Replacement Satellites.  Given the possibility of seeking 
additional licenses under the streamlined process, it does not appear necessary or efficient to adopt rules 
99
 Studies to accommodate requirements to study the spectrum in the space operation service for non-geostationary 
satellites with short duration missions, International Telecommunication Union, Provisional Final Acts, World 
Radiocommunication Conference, Resolution 659 (WRC-15). 
100
 Many small satellites are deployed in LEO, where they are more susceptible to upper atmospheric perturbations, 
solar winds, and other factors which can impact the orbit of the satellite and affect the duration of its operations.  See 
NOAA Space Weather Prediction Center, Geomagnetic Storms, 
http://www.swpc.noaa.gov/phenomena/geomagnetic-storms.
101
 See infra, Section III.A.1.e.
102
 With some exceptions, licenses issued under Part 25 of the Commission’s rules are currently issued for a period 
of 15 years, although the Commission reserves the right to grant or renew station licensees for less than 15 years.  47 
CFR § 25.121(a)(1), (b).  
Federal Communications Commission FCC 18-44
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for replacement satellites or expectation of replacement,
103
 or to provide for license extensions.
104
  
Accordingly, we propose that licenses granted under the streamlined process will be valid only for the 
original satellite(s) launched and operated by the licensee.
105
  We believe that this approach is consistent 
with the typical technical capabilities of small satellites, which often last no more than a few years in 
orbit, and also reflects the limited scope of the small satellite process.  The possibility of seeking 
additional licenses as new satellites are launched provides a mechanism to address rapid turnover in 
deployment and technology.  We seek comment on this approach toward license extensions and 
replacement spacecraft.
31. Applicability to Other Types of Missions.  We also recognize the possibility of 
commercial lunar missions or other non-Earth-orbiting missions in the future utilizing CubeSats or other 
small satellite designs.
106
  We seek comment on whether the small satellite process proposed here should 
be available to such missions and, if so, whether certain prerequisites for the small satellite process should 
apply only to Earth-orbiting satellites.  For example, we seek comment on whether applicants for 
satellites not intended to orbit the Earth could calculate anticipated mission lifetime based on anticipated 
operational lifetime rather than total on-orbit lifetime, and whether a different license term should be 
applicable to such missions.  We also anticipate that the proposed certification regarding disposal of the 
satellite through atmospheric re-entry
107
 would need to be modified for non-Earth-orbiting satellites, as 
well as the certification regarding deployment orbit.
108
  We seek comment.
d. Maximum Spacecraft Size
32. We tentatively conclude that satellite size, defined either by mass or by volume, should 
be a criterion for qualifying small satellites for streamlined processing.
109
   We recognize that there are a 
great variety of technologies and designs used for small satellites and seek comment on what the 
maximum size for small satellites should be, particularly to avoid situations where systems of satellites 
that would be more appropriately licensed under the standard Part 25 procedures seek to gain some 
advantage by applying through the small satellite streamlined process described below.  We propose a 
maximum mass of 180 kg for any satellite that would be authorized under the streamlined process.
110
  
NASA has used a maximum mass of 180 kg as one demarcation for the category of small satellites, which 
can encompass a variety of spacecraft,
111
 and we believe this upper mass should be sufficient to include 
typical small satellite designs, given the types of applications we have received to date, while allowing for 
flexibility to accommodate evolving satellite designs.  In addition, we anticipate that this maximum mass 
103
 Part 25 of the Commission’s rules currently provides for space station system replacement authorizations for non-
geostationary orbit satellites.  See 47 CFR § 25.128(e).
104
 Part 25 of the Commission’s rules generally permit licensees to file for license extensions for spaces stations as 
license modifications, subject to the requirements of section 25.117.  See 47 CFR § 25.117.
105
 Additionally, we do not anticipate that in-orbit spares would be authorized under a small satellite license.
106
 Development of these types of small satellite missions for non-commercial, scientific purposes has been ongoing.  
See, e.g., “NASA’s Space Cubes: Small Satellites Provide Big Payoffs,” NASA, Topics, Technology (Sept. 8, 
2015), https://www.nasa.gov/feature/nasa-s-space-cubes-small-satellites-provide-big-payoffs (describing selection 
of proposals for interplanetary CubeSat investigations as part of the NASA Small Innovative Missions for Planetary 
Exploration (SIMPLEx) program).
107
 See infra Section III.A.4.h.
108
 See infra Section III.A.4.e.
109
 We also propose to specify a minimum size for satellites authorized under this streamlined process, as discussed 
infra Section III.A.4.h.  The proposal specifying a minimum size is relevant to trackability of the satellites, and so is 
discussed in that context.
110
 See Appendix A, Proposed Rules, § 25.122.
111
 See NASA Small Spacecraft Technology Report at 1, 13.
Federal Communications Commission FCC 18-44
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would preclude systems that are not small satellites from applying under this streamlined process.  We 
seek comment on this proposed limit.  Would a greater maximum mass (e.g., 500 kg) or a smaller 
maximum mass be appropriate for characterizing small satellites?   Do other proposed criteria, such as the 
proposed zero reentry casualty risk criteria discussed below, effectively preclude larger satellites? 
e. Deployment Orbit and Maneuverability
33. We propose to require that applicants filing under the new proposed process certify that 
their proposed satellite will comply with one of several options regarding the deployment orbit and/or 
maneuverability of the satellite.  First, if the applicant intends to deploy the satellite(s) at an orbit below 
the orbit of the International Space Station (ISS), which is at an altitude of approximately 400 km, the 
applicant would certify that its satellite will be deployed at that lower-orbit location.  Second, if the 
applicant intends that its satellite(s) will be deployed from the ISS itself, or from a vehicle while that 
vehicle is docked with the ISS, the applicant would certify that its satellite will be deployed in this 
manner.
112
  Although the ISS is currently the only continuously occupied manned spacecraft in LEO, we 
recognize that China currently operates a spacecraft in LEO below the ISS that is periodically manned, 
and that other long-term manned spacecraft have been considered for operation in LEO as well.
113
  In the 
event that any such manned spacecraft are located at altitudes below where an applicant intends to operate 
a small satellite, we propose that the applicant must describe in narrative form the design and operational 
strategies it will use to avoid collision with manned spacecraft.
114
  Such strategies could include use of 
propulsion, reliance on orbits not occupied by manned spacecraft, coordination efforts with manned 
spacecraft, or other reasonable means of avoiding collision.  We seek comment on these proposals.  
34. Deployment of satellites lacking maneuvering capabilities above the ISS, to orbits from 
which they will eventually transit through the ISS altitude band, increase the likelihood that the ISS will 
need to conduct avoidance maneuvers, potentially disrupting ISS operations.
115
  For that reason, 
deployment of satellites without propulsion capabilities above the ISS may not be appropriate for 
streamlined consideration.  We propose as a third option, however, to authorize small satellites under the 
streamlined process to deploy at altitudes above the ISS if they certify that the satellite(s) have sufficient 
propulsion capabilities to perform collision avoidance maneuvers and deorbit within the license term 
proposed above.
116
  While many small satellites to date have not been equipped with onboard propulsion 
112
 Such spacecraft have similarly shorter orbital lifetimes. National Aeronautics and Space Administration, Orbital 
Debris: Quarterly News, “A Review of Space Environment Implications of CubeSat Traffic, 2003-2014,” Volume 
19, Issue 3, July 2015, at 6, http://orbitaldebris.jsc.nasa.gov/Quarterly-News/pdfs/ODQNv19i3.pdf (“An increase in 
2014 traffic is mitigated somewhat by the relatively short lifetimes of those CubeSats deployed from the ISS or 
visiting vehicles.”). 
113
 See, e.g., Jeff Foust, China launches Shenzhou-11 crewed spacecraft, SpaceNews, Oct. 16, 2016, available at 
http://spacenews.com/china-launches-shenzhou-11-crewed-spacecraft/ (noting that China already has a space-based 
laboratory in LEO that is manned periodically, and that China is engaged in efforts to develop and complete a 
permanent space station by the early 2020s); Irene Klotz, China Unveils Space Station Research Plans, SpaceNews, 
Nov. 12, 2013, available at http://spacenews.com/38131china-unveils-space-station-research-plans/ (noting that the 
planned China Space Station will be located in an orbit ranging from 350-450 km in altitude).
114
 See Appendix A, Proposed Rules, § 25.122.  An ex parte filing recommended that we consider future manned 
spacecraft and their likely orbits, and require that satellites have a maneuvering capability that is tested and 
demonstrated. See Alistair Funge, ex parte filing, IB Docket No. 18-86 (filed Apr. 3, 2018).
115
 See, e.g., The Aerospace Corporation, ELS File No. 0255-EX-CM-2017, Exh. Above ISS Deployment Letter at 2 
(filed Nov. 3, 2017) (documentation relating to approval of deployment for two satellites from the Orbital ATK 8 
Cygnus Cargo Resupply Vehicle after unberthing from the ISS, stating that the effect to ISS operations has a one 
percent likelihood of a debris avoidance maneuver per satellite deployed above the ISS).
116
 See Appendix A, Proposed Rules, § 25.122.
Federal Communications Commission FCC 18-44
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systems, new technologies are being developed that could provide a means for actively maneuvering.
117
  
We tentatively conclude that more limited maneuvering capabilities, such as those relying primarily on 
drag, would be insufficient to support deployment at higher altitudes under the streamlined small satellite 
process, as these methods will likely require closer Commission review, and seek comment on this 
tentative conclusion.  We also seek comment on whether there are any other factors that we should 
consider in specifying criteria related to orbits under this streamlined process.
f. Operational Debris and Collision Risk 
35. Under our current rules, we require Part 25 applicants to state that the satellite operator 
has assessed and limited the amount of debris released in a planned manner during normal operations.
118
  
Because the release of operational debris may require closer scrutiny and be inconsistent with a 
streamlined process, we tentatively conclude that the streamlined process should be limited to satellites 
that release no operational debris in a planned manner during their mission lifetime.  As the release of 
operational debris is extremely rare among all FCC-licensed satellites, including small satellites, we do 
not consider this limit as unduly constraining on the availability of the streamlined process.  We therefore 
propose that small satellite applicants must certify that their satellite(s) will release no operational debris, 
and we seek comment on this proposal.
119
  
36. Under current Part 25 requirements, applicants must also include a statement that the 
satellite operator has assessed and limited the probability of accidental explosions, including those 
resulting from conversion of energy sources on board the spacecraft into energy that fragments the 
spacecraft.
120
  We propose to retain this requirement for the streamlined process in the form of a 
certification of compliance.  We seek comment on whether a simple statement to this effect is 
appropriate,
121
  or whether there may be circumstances in which a more detailed disclosure and review is 
appropriate, for example for spacecraft that have propulsion systems or pressure vessels.   
37. Regarding risk of collision, we propose that applicants certify that the probability of each 
satellite’s risk of collision with large objects is less than 0.001, which is consistent with technical 
guidance developed by NASA for its space missions.
122
  We seek comment on whether the 0.001 metric is 
appropriate for satellites licensed in accordance with the streamlined process, or if a more stringent 
standard for collision risk may be appropriate, given that multiple satellites that may be deployed.  We 
further inquire into whether an applicant’s certification will be sufficient to address collision risk and 
debris issues, or whether we should seek additional information from satellite applicants under the 
streamlined process and if so what types of information would be necessary.  Alternatively, we ask 
whether such a certification is necessary given the other eligibility criteria for the streamlined process, 
such as limiting orbital altitude or requiring propulsion capability.
g. Trackability
38. We propose that all applicants seeking to be licensed under the streamlined small satellite 
process also certify that their satellites will be no smaller than 10 cm x 10 cm x 10 cm to ensure that the 
117
 For example, NASA has found that recent improvements in the efficiency of electric propulsion systems and 
miniaturization of chemical propulsion systems have opened the door to small satellites with significantly greater 
maneuverability than was previously possible.  See NASA Small Spacecraft Technology Report at 37-56.
118
 47 CFR § 25.114(d)(14)(i).
119
 Appendix A, Rule Revisions.
120
 47 CFR § 25.114(d)(14)(ii).
121
 See Appendix A, Proposed Rules, § 25.122. 
122
 NASA Technical Standard, Process for Limiting Orbital Debris, NASA-STD-8719.14A (with Change 1) (May 
25, 2012), https://standards.nasa.gov/standard/nasa/nasa-std-871914 (NASA Standard) and 
https://standards.nasa.gov/standard/nasa/nasa-hdbk-871914  (NASA Handbook).  
Federal Communications Commission FCC 18-44
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satellite will be trackable as a space object.
123
  This size is consistent with the CubeSat specification.
124
  
We note that while there may be methods for improving tracking of smaller objects, such as reflectors or 
transponders, these methods may require closer scrutiny and detailed analysis, and such analysis may be 
inconsistent with a streamlined process.  We further propose that the applicant would also be required to 
certify that the satellite will include a unique telemetry marker allowing it to be readily distinguished from 
other satellites or space objects.
125
  We believe these certifications will help ensure that satellite operators 
will be able to assist entities that track space objects to more easily identify and distinguish between the 
small satellites utilizing the streamlined process and other space objects.  We seek comment on these 
proposals.
h. Casualty Risk
39. We propose that applicants certify that their satellite(s) will be disposed of through 
atmospheric re-entry following completion of the mission.
126
  Under our current satellite authorization 
rules, including those that apply to experimental and amateur missions, applicants planning disposal of 
satellites through atmospheric re-entry must provide a statement assessing casualty risk, with an estimate 
of whether portions of the spacecraft will survive re-entry and reach the surface of the Earth, as well as an 
estimate of the resulting probability of human casualty.
127
  If a statement indicates a risk of human 
casualty, the spacecraft could result in a future claim being presented to the United States under the 
relevant United Nations Outer Space Treaties.
128
  In light of the casualty risk, it may be necessary to 
consider satellite modifications that could reduce the risk to zero, or insurance and liability arrangements.  
We tentatively conclude that consideration of such arrangements, which is likely to involve detailed 
factual inquiry and potentially complicated legal and financial arrangements, is not consistent with the 
proposed streamlined process.  Therefore, we propose that any small satellite applicant seeking to file 
under the streamlined process certify that it has conducted a casualty risk assessment using the NASA 
Debris Assessment Software (DAS)
129
 or another higher fidelity model,
130 
 and that the assessment 
resulted in a human casualty risk of zero.
131
  We seek comment on this proposal.
i. Cessation of Emissions
40. ITU Radio Regulation No. 22.1 requires that space stations be fitted with devices to 
ensure immediate cessation of their radio emissions by telecommand, whenever such cessation is required 
123
 See Space-track.org, Documentation – Frequently Asked Questions, https://www.space-
track.org/documentation#/faq, (“10 centimeter diameter” or ‘softball size’ is the typical minimum size object that 
current sensors can track and the JSpoC maintains in the catalog); Appendix A, Proposed Rules, § 25.122.  In an ex 
parte filing, Alba Orbital stated that satellites with a size under a 10 cm cube can be tracked and asked that satellites 
with a size of 5 cm or greater be included in the streamlined process.  See Alba Orbital, ex parte filing, IB Docket 
No. 18-86 (filed Apr. 2, 2018).  
124
 See, e.g., National Academies CubeSat Report at 6 (defining a CubeSat for purposes of the study as a spacecraft 
sized in units, with each unit having a volume of about 10 cm x 10 cm x 10 cm).
125
 Appendix A, Proposed Rules, § 25.122.
126
 Id.
127
 47 CFR § 25.114(d)(14)(iv).
128
 See Outer Space Treaty, art. 6, 7; Convention on International Liability for Damage Caused by Space Objects, 
art. 1, entered into force Oct. 9, 1973, 24 U.S.T. 2389, 961 U.N.T.S. 187.
129
 See NASA, Debris Assessment Software, https://www.orbitaldebris.jsc.nasa.gov/mitigation/das.html (DAS 
Website).
130
 See NASA Standard at 46 (noting that the DAS is based on a simplified model and that higher fidelity models are 
available).
131
 See Appendix A, Proposed Rules, § 25.122.
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under the radio regulations.
 132
  Section 25.207 of the Commission’s rules requires that space stations be 
capable of ceasing radio emissions by the use of appropriate devices (battery life, timing devices, ground 
command, etc.) that will ensure definite cessation of emissions.
133
  For the small satellite streamlined 
process, we propose that small satellites have the ability to cease transmissions by way of command 
(rather than by other potential means), to ensure the reliability of the satellite’s ability to cease 
transmissions instantaneously.  We propose that the applicant would need to certify that the satellite has 
the ability to receive command signals and cease transmissions as a result of a command.  We seek 
comment on this approach.  As part of this approach, we seek comment on whether we should require that 
satellites employ a “passively safe” system, i.e., the satellite cannot transmit unless it is actively 
commanded to transmit via a command, and will cease transmission unless within view of a ground 
station.
134
  
2. Small Satellite Application Processing
41. Background.  Under the Commission’s current regulatory approach, decisions on NGSO-
like satellite applications are made using processing round procedures.
135
  The Commission adopted this 
approach for NGSO-like satellite systems because of the possibility of otherwise unreasonably limiting 
additional market entry if licenses were granted on a first-come, first-served basis.
136
  For NGSO-like 
satellite systems, the Commission had envisioned that grant to one satellite system operator to provide 
service in a particular frequency band segment would preclude other satellite system operators from 
providing service in that frequency band.
137
  
42. The Commission has granted several waivers of the processing round rules for NGSO 
satellites, including small satellites, operating in the EESS.  For these small satellites, the Commission has 
relied on the applicants’ demonstrations that they can avoid interference events through means such as 
scheduling of transmissions, and would not preclude future entrants from using the same spectrum.
138
  For 
example, where a satellite operates with a limited number of earth stations for purposes of downlinking 
sensor data during relatively short periods of time, it may be possible for such a satellite system to 
accommodate future entrants utilizing the same frequency bands.  The spectrum demands of such systems 
differ substantially from the requirements for full-time system availability that characterize the NGSO-
like systems provided for by the processing round rule.
43. Discussion.  We propose that applications qualifying for the streamlined small satellite 
process be exempt from processing round procedures.  Instead, each applicant under the streamlined small 
satellite process would be required to (a) certify that operations of its satellite will not interfere with those 
of existing operators, (b) certify that it will not unreasonably preclude future operators from utilizing the 
assigned frequency band(s), and (c) provide a brief narrative description illustrating the methods by which 
132
 ITU R.R. No. 22.1.
133
 47 CFR § 25.207.  While section 25.207 applies to Part 25 licensees, a similar requirement applies to 
experimental licensees under Part 5 of the Commission’s rule.  See 47 CFR § 5.107 (requiring that licensee maintain 
control of the transmitter authorized under its license, including the ability to terminate transmissions in the event of 
interference).
134
 See ITU-R SA.2312-0 at 7 (describing a passively-safe system whereby the satellite is actively commanded to 
transmit only when in view of an associated earth station).
135
 47 CFR § 25.157.  Space Station Licensing Reform Order, 18 FCC Rcd at 10774, para. 23.
136
 Space Station Licensing Reform Order, 18 FCC Rcd at 10774, para. 25.
137
 Id.
138
 See, e.g., IBFS File No. SAT-LOA-20130626-00087 (granted Dec. 3, 2013) (granting a waiver of the modified 
processing round to Planet conditioned on the ability of future operators to enter the 8025-8400 MHz frequency 
band). 
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future operators will not be unreasonably precluded.
139
  Such methods could include the sharing of 
ephemeris data to avoid RF interference events,
140
 use of directional antennas, limiting operations to 
certain times throughout the day, limiting earth stations operating with the system to certain defined 
geographic locations, or some combination of these and other means that could be used to accommodate 
sharing in the assigned frequency band(s).  Regardless of the methods used, the Commission would make 
an assessment of the description provided to ensure that operators do not preclude others from operating 
in the band and thereby limit the risk of spectrum warehousing by licensees.  This approach also differs 
from the first-come, first-served queue used for GSO-like satellites, in that an earlier filed and granted 
application would not provide a basis for dismissing a later-filed request.  We seek comment on this 
proposal.  Applications would be processed in accordance with our existing procedures in other 
respects.
141
  We also seek comment on the certification and description requirements, and on the 
appropriate indicia for sharing.  
44. Although there would be no processing round under our proposed licensing approach, 
small satellite operators licensed pursuant to the streamlined process would still typically receive 
interference protections in accordance with the relevant service allocation in the U.S. Table of 
Allocations.  For example, small satellite applicants seeking to operate EESS systems in frequency bands 
with a secondary EESS allocation will be authorized on a secondary basis.  In bands where Part 25 
licensees are authorized pursuant to a processing round, however, the Commission anticipates that small 
satellites authorized on a streamlined basis would be subject to some limitations on a frequency-band 
specific basis, including, in appropriate circumstances, that operations are on a non-interference, 
unprotected basis with respect to those Part 25 systems.  We seek comment on this proposed approach to 
interference protection. 
45. For typical NGSO FSS, MSS, or other operations requiring full-time uninterrupted 
availability of assigned spectrum, the ability to share spectrum with all existing and future operations is 
more limited or nonexistent because of the complexities of these systems.  We tentatively conclude that 
the required indicia of sharing would not be present in these instances, and that such operations are more 
appropriately addressed for authorization under existing Part 25 procedures, including processing rounds.  
We recognize, however, that not all FSS and MSS operations require full time spectrum availability.  In 
these instances, where the other criteria are satisfied, authorization under the proposed streamlined small 
satellite process might be appropriate.  We seek comment on these tentative conclusions.  In determining 
whether an application is acceptable for filing within the streamlined small satellite process, we propose 
to rely on the applicant’s certification that it can reasonably share with existing and future operators, as 
described above, in addition to the other criteria we set forth in this Notice.  We propose to subsequently 
evaluate the applicant’s narrative description of sharing methods, however, particularly in the event that 
any comments or other pleadings address the applicant’s ability to share with other operators.  Under such 
an approach, we would dismiss an application without prejudice if we find that the applicant has failed to 
demonstrate that the proposed operations will not unduly limit other operations in the band.  In such case, 
the applicant could refile the application as an NGSO-like application in accordance with the 
requirements of the Commission’s processing round procedures.  We seek comment on this approach.  
Aside from the sharing certification and procedures discussed above, we ask whether additional 
mechanisms would be necessary to prevent authorized small satellite operations in a particular frequency 
band from having an aggregate interference footprint that is inconsistent with use by other existing or 
planned services.
139
 Appendix A, Proposed Rules, § 25.122.
140
 Ephemeris data give the orbital parameters of satellites at different times.  In the NGSO FSS R&O, the 
Commission extended the existing requirement regarding the maintenance of ephemeris data in section 25.271(e) of 
the Commission’s rules to NGSO FSS operations generally.  NGSO FSS R&O, 32 FCC Rcd at 7828, para. 58.
141
 See, e.g., 47 CFR §§ 25.112, 25.151 (acceptability for filing and public notice procedures).
Federal Communications Commission FCC 18-44
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46. Consistent with the above tentative conclusion that small satellites will not preclude 
others from operating in the band, we further propose to exempt small satellites from the limitations on 
unbuilt NGSO-like systems contained in section 25.159 of the Commission’s rules.
142
  We seek comment 
on this proposal.
3. Application Requirements
47. We propose that the FCC Form 312 and Schedule S would continue to serve as the basis 
for applications under the streamlined small satellite process.
143
  These forms include basic legal and 
technical information that provides Commission staff with information about the proposed operations.
144
48. In lieu of the narrative demonstrations required by the existing Part 25 rules, we propose 
that applicants may instead provide the various certifications described above as the qualifying criteria for 
the streamlined small satellite process.
145
  The certifications should ease the burden on applicants of 
completing a Part 25 application. Applicants under the proposed streamlined small satellite process would 
still need to provide some information in narrative form, such as how their operations will not preclude 
future operators in the assigned bands,
146
 but we do not envision that these additional narrative 
requirements will be unduly burdensome or undermine the objectives of this Notice.  We seek comment 
on the proposed changes.  We also seek comment on whether there are additional application 
requirements or revisions to application requirements that should be considered for the streamlined small 
satellite process.
4. Revised Bond Requirement
49. Under the Commission’s Part 25 rules, most NGSO licensees or recipients of market 
access must have on file a surety bond.
147
  A bond of $1 million must be filed at 30 days following grant 
and the amount of the bond that must be on file steadily escalates, with the maximum bond being $5 
million.
148
  The surety bond requires payment in the event that the licensee either fails to meet certain 
milestones, or surrenders the license before meeting certain milestones for the operation of its system,
149
 
specifically, launching 50 percent of the maximum number of satellites authorized for service, placing 
them in their assigned orbits, and operating them in accordance with the station authorization no later than 
six years after the grant of the authorization.
150
  Once the Commission determines that the milestone has 
(Continued from previous page)  
142
 47 CFR § 25.159(b).  This rule states that if applicants with an application for one NGSO-like satellite system 
license on file with the Commission in a particular frequency band, or one licensed-but-unbuilt NGSO-like satellite 
system in a particular frequency band, will not be permitted to apply for another NGSO-like satellite system license 
in that frequency band.  Id.
143
 The FCC Form 312, Main Form and Schedule S form the foundation for all space station license authorizations.  
See 47 CFR § 25.114(a).
144
 The Schedule S software is available electronically on the Commission’s website.  See FCC Schedule S System, 
https://enterpriseefiling.fcc.gov/schedules/.  Applicants are advised to use the software when submitting information 
to ensure that it is appropriately included in IBFS.  See FCC, Specific Instructions for Schedule S (April 2016), 
https://enterpriseefiling.fcc.gov/schedules//resources/Instructions%20for%20Schedule%20S%20vApr2016.pdf. 
145
 Appendix A, Proposed Rules, § 25.122.  This certification would be somewhat analogous in form to the 
Commission’s rules on the relocation of GSO space stations.  See 47 CFR 25.118(e)(5). 
146
 See Appendix A, Proposed Rules, § 25.122.
147
 47 CFR §§ 25.165(a)(3), 25.137(d)(1). 
148
 47 CFR §25.165(a)(1).
149
 47 CFR § 25.165(c).
150
 47 CFR § 25.164(b)(1).  There is also a nine-year build out milestone for NGSO systems, requiring that the 
licensee or market access recipient have its full system launched and operational by nine years after grant or accept a 
reduction in its authorized satellites to the number launched and operational at that time, but this milestone is not 
(continued….)
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been satisfied, the authorized entity will be relieved of its bond obligation.  The Commission established 
these requirements to deter warehousing by satellite operators before a proposed satellite has been 
launched and begun operations and to deter speculative satellite applications.
151
  
50. We propose a change to the bond requirement normally applicable to NGSO satellites 
authorized under Part 25.  Specifically, we propose a one-year “grace period” during which small 
satellites that qualify for the streamlined process as outlined in this Notice would not have to post a bond.  
This grace period would begin 30 days after the license is granted, since that is typically when a licensee 
must post a bond.  We seek comment generally on this proposal.  
51. This grace period may be warranted for two reasons.  First, most small satellite operators 
have a comparatively short window between filing of their application and deployment of their satellites.  
Applicants for small satellite short-duration missions frequently deploy and begin operations with their 
satellites within one year or less of obtaining a Commission license.  In these instances, once satellites are 
authorized, there is little opportunity for the applicant to warehouse spectrum that it does not intend to 
use.  Second, as described above, we propose that the estimated on-orbit lifetime of the individual 
satellites that may be authorized will be five years or less, and that licenses granted under the streamlined 
process may not be renewed or extended.
152
  Thus, to the extent that the satellite is authorized to operate 
in a particular frequency band, the licensee is unlikely to preclude the availability of resources to 
competitors or discourage innovation during this short amount of time.  Furthermore, the limitations we 
propose to place on the applicant’s license term, including the start of the five-year license term at launch 
of the first satellite, discussed supra, support this approach as well.  We seek comment on these rationales 
for postponing the bond requirements for small satellites that could be authorized under the streamlined 
small satellite process proposed in this Notice.  Are there any other considerations that the Commission 
should take into account when establishing the grace period?
52. Following the one-year grace period, if the authorized satellite(s) have not yet been 
deployed, we propose that operators could still launch and operate their satellites subject to the bond and 
milestone requirements applicable to NGSO satellites, provided that the satellite(s) can still meet the 
criteria for the small satellite process, including deorbit within the five-year license term (which we have 
proposed would begin when the first satellite is placed into its authorized orbit).  Under this proposal, the 
escalating bond would need to be filed with the Commission, at the amount that would be applicable for a 
Part 25 NGSO satellite one year after the license has been issued.
153
  We seek comment on this approach, 
and ask whether alternatively we should develop a different bond amount or a more or less rigorous 
approach to milestones for satellites licensed under the streamlined small satellite process. 
53. In addition, we propose that grantees failing to begin operations during the one-year 
grace period, because of launch delays, for example, may surrender their license to avoid the bond 
requirement.  Further, we suggest that grantees launching and operating one or more satellites within the 
one-year grace period, but failing to launch and operate 50 percent of their authorized satellites within 
that period, may choose to either be subject to the standard NGSO bond and milestone requirements or, in 
the case of licenses that specify multiple satellites, accept an automatic reduction in the number of 
authorized satellites to the number actually in orbit as of the close of the grace period.  This proposal 
would not preclude the filing of a new application for additional satellites.  We seek comment on these 
suggested outcomes.
tied to the surety bond.  Because we propose a five year on-orbit lifetime, we do not believe this milestone would be 
relevant for small satellites authorized under the streamlined process.  Id. at § 25.164(b)(2).
151
 Warehousing occurs when an entity holds exclusive authorization or priority for spectrum use or an orbital 
position, but is unable or unwilling to deploy its authorized satellite system in a timely manner.  Space Station 
Licensing Reform Order, 18 FCC Rcd at 10825, 10827, paras. 167, 173.
152
 See infra Section III.A.4.c.
153
 47 CFR § 25.165(a)(1).
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5. Technical Rules
54. Our Part 25 rules contain technical requirements governing the operations of both 
satellites and earth stations.  These rules specify, among other things, out-of-band emission limits, 
frequency tolerances, and power limits.
154
  We propose that existing generally applicable technical rules in 
Part 25 also be applicable to small satellites authorized under the streamlined process.  We seek comment 
on this proposal.  In addition, we note that many of the Part 25 technical rules such as out-of-band 
emission and power limits are in place to avoid interference occurring to other stations.  The interference 
environment in which a small satellite will operate will be a function of the frequency band in which it 
operates.  Consequently, we recognize that the technical requirements for small satellites may need to be 
adjusted for the different bands and we seek comment on some additional technical requirements later in 
this Notice in connection with the discussion of small satellite operations in particular frequency bands.
155
  
B. Frequency Considerations for Small Satellites
55. In this section, we address a number of issues relevant to frequency selection for small 
satellite systems generally having the characteristics described above.
156
  Specifically, we seek comment 
on the relationship between the proposed streamlined process and the particular bands for which 
applicants may apply.  We also consider issues related to coordination with Federal operations, and seek 
comment on several proposals to expand use of existing satellite allocated bands for small satellites.  We 
also consider whether some MSS and FSS frequency bands could be allocated for inter-satellite links for 
small satellites.  We also consider whether proposals may be appropriate related to inter-satellite links. 
1. Scope of Frequency Use
56. We seek comment on the specific frequency use characteristics of small satellites that 
would be authorized under the proposed small satellite process.  With respect to bands that are currently 
shared among services, we do not expect that small satellite operations would displace existing or planned 
non-satellite operations in a given frequency band.  We seek comment on whether small satellites should 
be required to make any additional demonstrations, either for all bands or in specific bands, about their 
ability to share with non-satellite services.  This could include, for example, demonstrating the ability to 
avoid interfering with incumbent non-satellite operators.
157
  We also seek comment on whether small 
satellites authorized under the streamlined process should be required to protect other services and accept 
interference from other services in all instances where they are operating in frequency bands that are 
shared with non-satellite services.  Alternatively, we seek comment on whether these small satellites 
should be afforded interference protection that is consistent with the relevant satellite allocation in a 
particular frequency band (e.g., primary or secondary with respect to other allocated services).
57. The current Part 25 rules include a list of frequency bands available for particular types 
of services, but indicate that operations can be authorized in other bands allocated for satellite services.
158
  
In order to assist small satellite operators in identifying possible frequency bands for use, we seek 
154
 See, e.g., 47 CFR §§ 25.202(d),(e),(f), 25.204. 
155
 See, e.g., infra Section II.B.4.b (discussion of possible service rules, including out-of-band emission limits, 
related to small satellite operations in the 1610.6-1613.8 MHz band).
156
 Consistent with a resolution adopted at WRC-15, the ITU-R is currently studying the spectrum requirements for 
TT&C for NGSO satellites with short duration missions, assessing the suitability of existing international allocations 
to the space operation service below 1 GHz, and may consider possible new allocations or an upgrade of the existing 
allocations to the space operation service within the frequency ranges 150.05-174 MHz and 400.15-420 MHz. ITU 
WRC-15, Resolution 659.  See WRC-15 Final Acts, Resolution COM6/19 (WRC-15), available at 
http://www.itu.int/pub/R-ACT-WRC.12-2015/en.  While we recognize these ongoing efforts at the ITU, we do not 
limit our consideration to bands identified in the WRC-15 resolution, or to the space operation service.  
157
 See id.
158
 See 47 CFR § 25.202.
Federal Communications Commission FCC 18-44
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comment on including a non-exclusive list of frequencies in section 25.202 of the Commission’s rules.  
We seek comment on the types of bands that should be specified in any such rule.  We also seek comment 
on an alternative proposal to omit a specific list and consider applications on a case-by-case basis, bearing 
in mind the relevant frequency allocations.  As a third alternative, we seek comment on whether the 
proposed process should be limited to specific frequency bands.  We also seek comment on the type and 
quantity of spectrum that will be needed for small satellites to operate.  Commenters should include data, 
analysis, and engineering studies on the expected demand for small satellites.  We request that 
commenters address their need to access specific bands, bearing in mind the case of bands that have other 
allocations and services.  
58. In addition to the sharing characteristics described above, we anticipate that the actual 
amount of spectrum used by any particular small satellite will be small, generally no more than a few 
megahertz and in some cases only a few tens-of-kilohertz, and RF output power will be low.  Notably, the 
ITU has found that for a short duration missions (three years or less) operating on frequencies below 1 
GHz, a typical small satellite space segment mission uses a bandwidth of less than 100 kilohertz, a non-
directional type antenna with a gain under 3 dBi, and RF output power of 1 W.
159
  For small satellites 
operating on frequencies between 1 and 3 GHz, the ITU found generally a wider bandwidth of less than 
7.5 megahertz is used, with non-directional antennae gain under 10 dBi, and an RF output power of less 
than 1 W.
160
  These technical characteristics, such as low power and low bandwidth, are generally 
consistent with the small satellites granted experimental licenses by the Commission,
161
 and are also 
consistent with the type of operations we envision being authorized pursuant to the streamlined small 
satellite process described in this Notice.  We understand that in some instances other uses may be 
anticipated, for example, where data downlinks require larger bandwidths, and so we also seek comment 
on whether modifications to the proposals discussed in this section would need to be made to 
accommodate these other types of operations.  We also seek comment on the extent to which larger 
bandwidth transmissions could be conducted via inter-satellite links or alternatives such as optical links.
59. In the discussion above, we sought comment on whether the existing Part 25 technical 
rules should apply to small satellites.  Here we also ask whether particular service rules, on a band-
specific basis, may be needed to ensure protection of incumbent users.  For example, geographic isolation 
of small satellite earth stations, power level restrictions on transmissions to and from small satellites, 
temporal restrictions on small satellite communications with earth stations, antenna specifications or other 
limitations on satellite design parameters, and/or other technical requirements may enable protection of 
incumbent operations, depending on the RF environment in each band. 
2. Compatibility and Sharing with Federal Users
60. The U.S. Table is divided into the Federal Table of Frequency Allocations and the non-
Federal Table of Frequency Allocations.
162
  Some bands are allocated to both Federal and non-Federal 
uses.  In addition, some footnotes to the U.S. Table specify that use of a particular band by non-Federal 
users is subject to successful coordination with Federal users.  An established set of procedures guides the 
interaction between the FCC and NTIA in developing regulations for services in shared bands, and for 
authorizing frequency use by Federal agencies and Commission licensees.
163
  Under the Memorandum of 
159
 See ITU-R Characteristics Report at 9.
160
 Id.
161
 Texas A&M University AggieSat Lab, ELS File No. 0305-EX-PL-2014 (granted Oct. 28, 2014); Tyvak Nano-
Satellite Systems, Inc., ELS File No. 0399-EX-PL-2016 (granted Oct. 13, 2016); Morehead State University Space 
Science Center, ELS File No. 0635-EX-PL-2013 (granted February 18, 2014).
162
 See generally U.S. Table, 47 CFR § 2.106.
163
 For example, the NTIA Manual describes technical requirements for Federal radio services. See generally NTIA 
Manual.
Federal Communications Commission FCC 18-44
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Understanding (MOU) between NTIA and the Commission, the Commission and NTIA give notice to 
each other of “all proposed actions that could potentially cause interference” to non-Federal and Federal 
operations, respectively.”
164
61. In discussing the compatibility of small satellites with other operations, however, we note 
that a number of the frequency bands where small satellites have been authorized, and where there are 
non-Federal allocations for services such as EESS and space operations,
165
 are shared with Federal users.  
Small satellite operations in these bands must be compatible with Federal uses.  We seek comment on any 
rules that could be adopted by the Commission specific to these frequency bands that would better enable 
small satellite operators to consider, in advance of coordination, whether they may be able to operate in 
these bands while still protecting Federal operations.  Examples of such rules could include traditional 
approaches requiring geographic isolation of non-Federal earth stations from Federal earth stations or 
other sites, or approaches such as permitting a satellite to transmit only when it is receiving uplink 
communications from certain pre-coordinated earth station sites.
166
  These examples would not 
necessarily replace the need to coordinate with Federal systems on a case-by-case basis, but we seek 
comment on whether these approaches or cooperative arrangements, public-private partnerships, scientific 
research programs, or other hybrid Federal/non-Federal arrangements could help streamline sharing.  
How would the establishment of certain service rules or other requirements on a band-specific basis help 
to facilitate compatibility among separate systems and development of new types of shared and efficient 
uses of space and spectrum resources?  We seek comment on these issues and on whether and how such 
rules and requirements may vary depending on the specific frequency bands being considered.
3. Small Satellite Operations as an Application of the MSS 
62. We believe that it may be appropriate to permit small satellite operations in selected 
bands allocated to the MSS, where the characteristics of the small satellite operations, as described in this 
Notice, would limit any potential for interference into existing MSS operations, and would ensure that the 
small satellite operations would have less potential for interference to either in-band or adjacent band 
services than operations that would typically be considered in the MSS.  As discussed infra, this proposal 
corresponds to allocations to the MSS (Earth-to-space) in the 149.9-150.05 MHz and 1610.6-1613.8 MHz 
frequency bands.  Accordingly, in these specific instances, our proposal would be to add a use footnote to 
the U.S. Table stating that small satellites authorized under the new process in section 25.122 of the 
Commission’s rules may be considered an application of the MSS.  In connection with this proposal, we 
seek comment on whether such operations should in all cases be on a non-interference, unprotected basis, 
or whether the operations may have status in the frequency band, provided that the satellites operate 
consistent with any limitations on the MSS allocations and have demonstrated compliance with the small 
satellite process in section 25.122.
4. Discussion of New Small Satellite Operations in Select Bands
63. In this section, we highlight frequency bands with existing non-Federal frequency 
allocations for space operations or other satellite services (e.g., MSS) in the U.S. Table that we believe 
may accommodate small satellite operations in addition to the services that have been authorized in the 
164
 “Memorandum of Understanding between the Federal Communications Commission and the National 
Telecommunications and Information Administration,” January 31, 2003 (MOU), available at 
https://apps.fcc.gov/edocs_public/attachmatch/DOC-230835A2.pdf; see also FCC News Release, “FCC and NTIA 
Sign New Memorandum of Understanding on Spectrum Coordination,” (Jan. 31, 2003), available at 
https://www.fcc.gov/document/fcc-and-ntia-sign-new-memorandum-understanding-spectrum-coordination. 
165
 The space operation service is a radiocommunication service concerned exclusively with the operation of 
spacecraft, in particular space tracking, space telemetry, and space telecommand.  47 CFR § 2.1; ITU R.R. No. 1.23.
166
 This approach could be consistent with our proposal that small satellites authorized under the streamlined process 
have implemented a passively-safe system whereby the satellite is actively commanded to transmit by command 
originating from the ground.  See supra Section III.A.1.i; ITU-R Characteristics Report at 7.
Federal Communications Commission FCC 18-44
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frequency bands to date.  For the frequency bands under consideration, we seek comment on potential 
service rules or limitations that could be placed on operations in these bands in order to better facilitate 
coordination and sharing with incumbent operations.  In some instances, we also seek comment on 
proposing additional service allocations.
a. 137-138 MHz and 148-150.05 MHz
64. Background.  The 137-138 MHz band is allocated for downlinks in Federal and non-
Federal portions of the U.S. Table on a co-primary basis to the space operation service (space-to-Earth), 
meteorological satellite service (space-to-Earth), and the space research service (space-to-Earth).
167
  
Several sub-bands within the 137-138 MHz band are also allocated to the MSS (space-to-Earth), either on 
a co-primary or secondary basis, in the Federal and non-Federal Tables, but are limited to non-voice, non-
geostationary (NVNG) satellite systems.
168
  The 148-150.05 MHz band is allocated for uplinks to the 
MSS (Earth-to-space) on a primary basis in the Federal and non-Federal Tables, also limited to NVNG 
satellite systems.
169
  The 148-149.9 MHz frequency band is also allocated by footnote to the space 
operation service (Earth-to-space) on a co-primary basis in the Federal and non-Federal Tables, subject to 
agreement obtained under No. 9.21 of the ITU Radio Regulations, limited to bandwidths not exceeding 
25 kilohertz for any individual transmission,
170
 and to the fixed service (FS) and mobile service (MS) on a 
co-primary basis for Federal use.
171
  The 149.9-150.05 MHz band is also allocated to the radionavigation-
satellite service (RNSS) on a co-primary basis in the Federal and non-Federal Tables.
172
  Under an 
international footnote, MSS operations in the 149.9-150.05 MHz band must be coordinated under No. 
9.11A of the ITU R.R., and use of the band by the MSS shall not constrain the development and use of 
the band by the radionavigation satellite-service.
173
65. The 137-138 MHz and 148-150.05 MHz bands were the subject of a processing round 
and rulemaking in 1997 and 1998, which resulted in the grant of several licenses for the provision of MSS 
in these bands.
174
  Of the initial licensees, only one, ORBCOMM License Corp. (ORBCOMM), remains 
licensed to provide commercial NVNG MSS in the 137-138 MHz or 148-150.05 MHz bands.  In 2008, 
ORBCOMM was granted a modification of its license for an NVNG MSS system to construct, launch, 
and operate additional satellites capable of operating in the 137-138 MHz and 148-150.05 MHz frequency 
bands.
175
  ORBCOMM subsequently received another modification of its license in 2016.
176
  Considering 
167
 47 CFR § 2.106.
168
 47 CFR § 2.106, footnote US320.  MSS operations in the 137-138 MHz band are also subject to coordination 
under ITU R.R. No. 9.11A.  Under the Commission’s rules, stations of a secondary service shall not cause harmful 
interference to and cannot claim protection from harmful interference from stations of primary service to which 
frequencies are already assigned or to which frequencies may be assigned at a later date, but can claim protection 
from harmful interference from stations of the same or other secondary service(s) to which frequencies may be 
assigned at a later date.  47 CFR § 2.105(c)(2)(i)-(iii).
169
 47 CFR § 2.106, footnote US320.  MSS operations in the 148-149.9 MHz band must be coordinated under No. 
9.11A of the ITU R.R., and the use of the band by the MSS shall not constrain the use and development of the band 
by the fixed, mobile, and space operation services.  See id., international footnote 5.219.
170
 47 CFR § 2.106, international footnote 5.218.  
171
 47 CFR § 2.106.
172
 Id.
173
 47 CFR § 2.106, international footnote 5.220 (not in U.S. Table).
174
 Amendment of Part 25 of the Commission’s Rules to Establish Rules and Policies Pertaining to the Second 
Processing Round of the Non-Voice, Non-Geostationary Mobile Satellite Service, Report and Order, 13 FCC Rcd 
9111 (1997).
175
 Applications by ORBCOMM License Corp., Order and Authorization, 23 FCC Rcd 4804 (IB, OET 2008) 
(ORBCOMM 2008 Order).  
Federal Communications Commission FCC 18-44
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all the various modifications to its license, ORBCOMM is specifically authorized to operate in certain 
sub-bands.
177
  ORBCOMM was also granted authority to operate throughout the 137-138 MHz and 148-
150.05 MHz frequency bands until commencement of operations by another U.S.-licensed NVNG MSS 
system, consistent with the spectrum sharing plan adopted by the Commission in a 1997 order 
establishing rules and policies for the licensing and operation of satellite systems in the NVNG MSS.
178
  
To date, no other NVNG MSS systems have operated in these frequency bands, although a handful of 
experimental small satellites have proposed operations in these frequency bands.
179
  
66. Discussion.  In light of the existing frequency allocation for space operation downlinks in 
the 137-138 MHz band, and the allocation for space operation uplinks the 148-149.9 MHz band in 
accordance with international footnote 5.218, we seek comment on use of these bands for small satellite 
operations.  Additionally, we propose to permit small satellite uplinks in the 149.9-150.05 MHz 
frequency band as an application of the MSS.
180
  The ORBCOMM system is currently operating in 
portions, if not all, of these frequency bands.  As these frequency bands were originally considered for use 
by multiple satellite systems, we request comment generally on whether, and if so, how, small satellite 
space operations could share this spectrum while protecting ORBCOMM’s existing and future MSS 
operations.  As part of this proposal, we consider whether small satellites could utilize spectrum in those 
frequency bands where ORBCOMM has been authorized to operate pending commencement of 
operations by another U.S.-licensed NVNG MSS system (i.e., the individual sub-bands within the 137-
138 MHz and 148-150.05 MHz frequency bands that were not specifically identified in ORBCOMM’s 
license or subsequent modifications to its license).
181
  We seek comment on this proposal. 
67.  In addition, we note the additional requirements applicable to these frequency bands.  
We note that operations in the downlink band, 137-138 MHz, in the MSS are subject to a number of 
service rules to effectuate coordination with NOAA.
182
  We seek comment on whether any of these 
service rules should be similarly applied to potential operations by small satellites in this frequency 
176
 See ORBCOMM License Corp., IBFS File Nos. SAT-MOD-20111021-00207, SAT-AMD-2013021200020, and 
SAT-AMD-20151223-00087 (granted-in-part, dismissed-in-part May 5, 2016).  In addition to a discrete set of 
frequency bands granted to ORBCOMM for use on a primary basis in 2008, ORBCOMM was subsequently granted 
authorization for a 50 kilohertz downlink centered at 137.4 MHz and a feeder link centered at 150.025 MHz.  See id. 
(partial grants of Apr. 25, 2013 and Dec. 17, 2015).
177
 See ORBCOMM 2008 Order, 23 FCC Rcd at 4812-13, paras. 22-23; ORBCOMM License Corp., SAT-MOD-
20111021-00207, SAT-AMD-2013021200020, and SAT-AMD-20151223-00087 (partial grant of Apr. 25, 2013 and 
partial grant of Dec. 17, 2015). 
178
 Amendment of Part 25 of the Commission’s Rules to Establish Rules and Policies Pertaining to the Second 
Processing Round of the Non-Voice, Non-Geostationary Mobile Satellite Service, Report and Order, 13 FCC Rcd 
9111 (1997).  The Little LEO satellite service uses constellations of low-earth orbiting (LEO) satellites to provide 
commercial radiolocation and two-way data messaging services.  Operating at altitudes much lower than those in 
geostationary orbits, Little LEO satellites are typically deployed in constellations so that as one satellite moves out 
of view of a terrestrial station, another satellite will come over the horizon to maintain coverage.  Amendment of 
Part 2 of the Commission’s Rules to Allocate the 455-456 MHz and 459-460 MHz bands to the Mobile-Satellite 
Service, Order, 17 FCC Rcd 8899, 8900, n.4 (2002).
179
 See, e.g., Kubos Corporation, ELS File No. 0489-EX-CN-2017 (pending) (proposing uplink operations at 149 
MHz).
180
 See Appendix A, Proposed Rules, § 2.106.
181
 See See ORBCOMM 2008 Order, 23 FCC Rcd at 4812-13, paras. 22-23; ORBCOMM License Corp., SAT-MOD-
20111021-00207, SAT-AMD-2013021200020, and SAT-AMD-20151223-00087 (partial grant of Apr. 25, 2013 and 
partial grant of Dec. 17, 2015).
182
 See 47 CFR § 25.259.
Federal Communications Commission FCC 18-44
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band.
183
  The uplink band, 148-150.05 MHz, is subject to coordination, to the extent specified in the U.S. 
Table and/or International Table, under Nos. 9.11A and 9.21 of the ITU Radio Regulations.
184
  We seek 
comment on whether these coordination requirements will significantly impede use of this band by small 
satellites for short duration missions.
185
b. 1610.6-1613.8 MHz
68. Background.  The 1610.6-1613.8 MHz frequency band is allocated for Federal and non-
Federal use on a co-primary basis to the MSS (Earth-to-space), the aeronautical radionavigation service, 
the radiodetermination-satellite service (Earth-to-space), and the radio astronomy service (RAS) on a co-
primary basis.
186
  This band is part of what is known as the “Big LEO” spectrum.
187
  In the United States, 
the 1610-1626.5 MHz frequency band is currently divided between the time division multiple access 
(TDMA) MSS system operated by Iridium Constellation LLC (Iridium) with service links in both 
directions
188
 and the code division multiple access (CDMA) MSS system operated by Globalstar Inc. 
(Globalstar).
189
  Currently, Globalstar is authorized to operate at 1610-1617.775 MHz on an exclusive 
basis.
190
  In accordance with the non-Federal portion of the U.S. Table, the lower portion of the spectrum, 
at 1610.6-1613.8 MHz is also used by RAS receivers.
191
  Globalstar’s operations in this band must protect 
RAS sites in the United States.
192
  
69. Discussion.  We seek comment on whether small satellites could operate in this band as 
an application of the MSS
193
 under the existing uplink allocation.  These would be small satellite Earth-to-
space links operating independently of the Globalstar system.
194
  We tentatively conclude that this band 
offers spectrum for small satellites to use, provided that the small satellite uplink operations can protect 
the existing MSS operations, as well as RAS operations.  To these ends, we believe that service rules 
would be appropriately applied to any small satellites seeking to operate in these bands as an application 
183
 Id.
184
 As noted, MSS operations in the 148-149.9 MHz band are subject to coordination under No. 9.11A of the ITU 
R.R., 47 CFR § 2.106, international footnote 5.219, and pursuant to an international footnote, MSS operations in the 
149.9-150.05 MHz band are subject to coordination under No. 9.11A of the ITU R.R., 47 CFR § 2.106, international 
footnote 5.220 (not in U.S. Table).  Stations operating in the space operation service in the 148-149.9 MHz band are 
subject to agreement obtained under No. 9.21 of the ITU R.R., 47 CFR § 2.106, international footnote 5.218.
185
 See ITU R.R. No. 9.21.  We note that in Resolution 659 (WRC-15) relating to suitable allocations for the space 
operation service for short duration missions, as discussed infra, the ITU-R recognized that allocations where No. 
9.21 applies are not suitable for use by short duration missions.  See ITU-R Resolution 659 (WRC-15).
186
 47 CFR § 2.106.
187
 The Commission has previously classified some satellites operating in LEO as Big LEOs or Little LEOs.  Big 
LEOs provide voice and data communications above 1 GHz, while Little LEOs provide data communications below 
1 GHz.  Review of Spectrum Sharing Plan Among Non-Geostationary Satellite Orbit Mobile Satellite Service 
Systems in the 1.6/2.4 GHz Bands, Report and Order, Fourth Report and Order, and Further Notice of Proposed 
Rulemaking, FCC 04-134, at para. 1, n.1 (2004).
188
 See Iridium Constellation LLC, Order and Authorization, IBFS File Nos. SAT-MOD-20131227-00148, SAT-
AMD-20151022-00074, DA 16-875 (IB, Sat Div. and OET, 2016).
189
 See Globalstar Licensee LLC and Iridium Constellation LLC, Order of Modifications, 23 FCC Rcd 15207, 
15208, 15222, paras. 3, 44 (2008).
190
 Id. at 15207, para. 1.
191
 47 CFR § 2.106.
192
 See 47 CFR § 25.113(a)(1).
193
 See Appendix A, Proposed Rules, § 2.106.
194
 Operations of small satellites using the Globalstar system are addressed in Section III.B.8 infra.
Federal Communications Commission FCC 18-44
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of the MSS.  We seek comment on what service rules would be necessary to protect MSS and RAS 
operations.  For example, small satellites seeking to operate in this band could demonstrate that they are 
not within certain exclusion zones related to United States RAS sites, such as those identified in section 
25.213.  Earth stations transmitting in these bands for any system could be limited in number and be 
specifically identified in the application materials for applicants seeking to operate in this band.  Small 
satellite operations in the band could be required to observe out of band emissions limits in section 25.216 
to protect the radionavigation satellite service (RNSS).  Moreover, we could require that all earth stations 
operating with a small satellite system have directional antennas and that the system must have the ability 
to avoid in-line interference events to the existing operators in the band, primarily through operations at 
higher latitudes.  We seek comment on these proposals.  We also seek comment on whether authorization 
should be limited to communications with U.S. earth stations or if other limitations should be adopted.  
We seek further comment on the potential impact of small satellite operations in this band to existing or 
planned operations in adjacent or nearby bands, including to Iridium’s operations in the adjacent band 
above,
195
 and to RNSS systems operating below 1610 MHz.  We seek comment on whether application of 
the existing out of band emissions limits in section 25.216 of the Commission’s rules would be sufficient 
to protect these systems from harmful interference.
5. Use of MSS and FSS Frequency Bands for Inter-Satellite Links with Small 
Satellites 
70. Background.  The Commission’s rules and the ITU Radio Regulations define “inter-
satellite service” as a radiocommunication service providing links between satellites.
196
  Section 25.279(a) 
of the Commission’s rules states that space stations may use frequencies in the inter-satellite service as 
indicated in section 2.106, and other frequencies where inter-satellite links are part of the service 
definition.
197
  For example, the definition of FSS states that in some cases FSS may include satellite-to-
satellite links, which may also be operated in the inter-satellite service.
198
  The definition of MSS likewise 
includes radiocommunication service “between space stations used by this service,”
199
 thereby permitting 
frequencies allocated to MSS to be used for inter-satellite links.  For service allocations in some 
frequency bands, the Table of Frequency Allocations specifies a directional limitation on operations.
200
  
For example, an allocation for FSS may be limited by parenthetical to the space-to-Earth direction.  In 
that instance, inter-satellite communications would not be in accordance with the Table of Allocations.
 201
  
Where a parenthetical to the FSS allocation specified “space-to-space” communications, the operation of 
inter-satellite links would be in accordance with the allocation, subject to any other limitations.
 
71. In the MSS, Globalstar has operated several experimental inter-satellite links with small 
195
 Iridium and Globalstar share 0.95 megahertz of spectrum at 1617.775-1618.725 MHz.  See Globalstar Licensee 
LLC, GUSA Licensee LLC and Iridium Constellation LLC, Iridium Satellite LLC, Iridium Carrier Services LLC, 
Modification of Authority to Operate a Mobile Satellite System in the 1.6 GHz Frequency Band, Order of 
Modifications, 23 FCC Rcd 15207 (2008).  Iridium has an exclusive assignment of MSS spectrum in the 1618.725-
1626.5 MHz band.  Id.
196
 47 CFR § 25.103.
197
 47 CFR § 25.279(a).
198
 47 CFR § 25.103.
199
 47 CFR § 25.103.
200
 ITU R.R. No. 5.49 (“In the case where there is a parenthetical addition to an allocation in the Table, that service 
allocation is restricted to the type of operation so indicated.”)
201
 While not in conformance with the International Table, space stations at both ends of the inter-satellite link 
would still be subject to applicable notification requirements under the Radio Regulations.
Federal Communications Commission FCC 18-44
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satellites.
202
  The small satellites use Globalstar equipment developed for earth station operations to 
transmit and receive data by means of the Globalstar system, including Globalstar satellites and ground 
infrastructure.  The experimental communications have taken place on frequencies currently authorized to 
Globalstar for MSS, typically in the 1615-1617.75 MHz or 2483.5-2495 MHz bands.  Iridium has 
similarly been authorized on an experimental basis to utilize its MSS satellites to communicate with small 
satellites equipped with Iridium user terminals in spectrum authorized for use by Iridium, including in the 
1618.725-1626.5 MHz band.
203
  In filings for experimental authorizations, Iridium and Globalstar 
acknowledge that their Part 25 authorizations currently do not cover these types of space-to-space 
communications.
204
  The frequency bands that have been used for inter-satellite communications between 
small satellites and the Iridium and Globalstar system do not include an allocation for space-to-space 
operations in the MSS.
205
  Therefore, these operations to date, licensed under the experimental process, 
have not been in conformance with the Table of Frequency Allocations.
72. Discussion.  We tentatively conclude that it would serve the public interest to develop an 
allocation for space-to-space operations in the MSS in the frequency bands that have been used for 
communications with the Globalstar and Iridium systems.  There are a number of benefits to inter-satellite 
operations, given the capabilities and existing infrastructure of these MSS systems and the ability of small 
satellite operators to obtain components needed to communicate with these systems.  We believe that 
encouraging relay operations using Iridium, Globalstar, or other systems can alleviate some of the 
difficulties faced by small satellite operators in identifying frequencies for Earth-to-space and space-to-
Earth links and building or seeking out ground station infrastructure.  We seek comment on these 
tentative conclusions.  In addition, given the interest in similar relay communications with satellites 
operating in the FSS, we ask whether there are other frequency bands that may be appropriate to identify 
for facilitating inter-satellite communications between satellites operating in the FSS and small satellites.  
Alternatively, we ask whether there is a definitional change we could develop and propose for MSS, FSS, 
or ISS that would enable broader change at the ITU for future accommodation of these services within 
existing allocations.  We also seek comment on whether there are additional requirements, for example, 
technical requirements, that could be adopted to facilitate the use of MSS or FSS frequency bands for 
inter-satellite links without creating potential interference to other operations.
73. Additionally, we seek comment on providing for the authorization of inter-satellite 
service links in the frequency bands that have been used for communications with the Globalstar and 
Iridium systems through a footnote to the U.S. Table.  We also seek comment on the bands within the 
MSS allocations currently used by Globalstar and Iridium, such as 1613.8-1626.5 MHz and 2483.5-2495 
MHz, that would be appropriate for this proposal.  We recognize, for example, that frequency bands such 
as 1610-1613.8 MHz may not be appropriate for such operations, in order to ensure protection of radio 
astronomy installations.   
202
 See, e.g., Globalstar, Inc., ELS File No. 0242-EX-PL-2016, Exh. Description of Research Project v.4 (granted 
June 24, 2016) (for communications with three experimental small satellites); Globalstar, Inc., ELS File No. 0468-
EX-PL-2015, Exh. Clarification of License Request Purpose (granted Sept. 28, 2015) (for communications with a 
small satellite).
203
 See, e.g., Iridium Satellite LLC, ELS File No. 0064-EX-ST-2015, Exh. Request for Special Temporary Authority 
(granted Jan. 22, 2015) (Iridium satellite phone installed on a university’s small satellite used to communicate 
between the satellite and the Iridium constellation).
204
 See, e.g., Globalstar, Inc., ELS File No. 0242-EX-PL-2016, Exh. Description of Research Project v.4; Iridium 
Satellite LLC, ELS File No. 0064-EX-ST-2015, Exh. Request for Special Temporary Authority.
205
 See 47 CFR § 2.106.
Federal Communications Commission FCC 18-44
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IV. FEES
74. We note two important matters related to our statutory fees.
206
  
75. Application Fees.  With respect to the one-time application processing fee, the 
Commission’s fee schedule is set forth in section 8 of the Act.
207
  The fee schedule includes a category for 
“Low-Earth Orbit Satellite Systems,” which the Commission has interpreted to mean NGSO space 
stations.  The Commission’s International and Satellite Services Fee Filing Guide describes an NGSO 
space station as: “NGSO space stations orbit the earth in non-geostationary orbits,”
208
 and the associated 
one-time processing fee for authority to deploy and operate these space stations is $454,705.00.  Because 
we expect most small satellites would use low-earth orbits, we would expect them to fall into this current 
application fee category.   
76. Recently, Congress passed the Repack Airwaves Yielding Better Access for Users of 
Modern Services Act of 2018, or the RAY BAUM’S Act of 2018, which authorized the Commission to 
“by rule amend the schedule of application fees . . . so that the schedule reflects the . . . addition of new 
categories of applications.”
209
  Such application fees should “recover the costs of the Commission to 
process applications.”
210
  Given our expectation that small satellite applications will take less time and 
fewer Commission resources to process than a typical NGSO system, we propose to establish a new 
application fee for small satellite applications well below the application fee of $454,705 for Low-Earth 
Orbit Satellite Systems—specifically we estimate a fee of $30,000 would likely recover the costs to the 
Commission to process these applications.
211
  We anticipate that processing a small satellite application 
may require comparable Commission resources to processing an application for a modification of an 
NGSO system, for which the application fee is currently $32,480.  Modification applications typically do 
not require review of a full set of data, but only those aspects of the operations that are changing, and 
frequently do not require a processing round.  This more limited review is less resource intensive, and 
similarly, we expect that review of satellite application filed under the proposed streamlined process 
would be more limited given the streamlined application and lack of processing rounds.  We seek 
comment on this application-fee proposal, as well as whether a higher or lower fee would be appropriate.  
We further seek comment on the costs and benefits of this proposal.  We also note that the Commission 
will be developing an accounting system to track the costs of applications, including small satellite 
applications,
212
 and we expect that our experience actually processing these new applications will 
eventually inform the appropriate application fee.
77. Regulatory Fees.  The second fee-related matter concerns annual regulatory fees for 
small satellites.  Entities authorized to operate NGSO systems under Part 25 currently must pay an annual 
206
 Applicants for U.S. market access do not currently incur application or regulatory fees.  See, e.g., Procedures for 
Assessment and Collection of Regulatory Fees, 28 FCC Rcd 7790, 7809, para. 48 (2013) (“Despite the regulatory 
benefits provided by the Commission to non-U.S. licensed satellite systems serving the United States they do not 
incur the regulatory fees (or application fees) paid by U.S.-licensed satellite systems.”).
207
 47 U.S.C. § 158.
208
 2016 Application Fees Order, 31 FCC Rcd. 7534.
209
 Consolidated Appropriations Act, 2018, 115
th
 Cong., Division P, section 102 (amending section 8(c) of the Act).
210
 Id. (amending section 8(a) of the Act).
211
 We note that the effective date of this statutory change is October 1, 2018, and we make clear that we are not 
proposing to make any changes to our application fees before that date.  Id. (section 103 of the Act, effective date). 
212
 Id. (adding section 9A(f) to the Act).  
Federal Communications Commission FCC 18-44
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regulatory fee which, for fiscal year 2017, was $135,350.00 per operational system.
213
  As a general 
matter, the Commission does not entertain issues about specific parts of the regulatory fee schedule apart 
from its annual review of the overall regulatory fee schedule,
214
 given the interdependency of the fees 
charged across individual categories.
215
  Accordingly, any comments regarding regulatory fees, as 
applicable to small satellites, should be filed in the proceedings we open for conducting the annual review 
of such fees.
216
    
V. CONCLUSION
78. Small satellites represent a dynamic sector in the satellite industry.  Our goal is to 
encourage innovation in this realm by developing processes that can accommodate new types of missions 
while still ensuring that operators do not experience harmful interference and that the operations are in the 
public interest.  Accordingly, we seek comment on these proposals.
VI. PROCEDURAL MATTERS
A. Ex Parte Rules – Permit-But-Disclose
79. Pursuant to section 1.1200(a) of the Commission’s rules, this Notice shall be treated as a 
“permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules.
217
  Persons making 
ex parte presentations must file a copy of any written presentation or a memorandum summarizing any 
oral presentation within two business days after the presentation (unless a different deadline applicable to 
the Sunshine period applies).  Persons making oral ex parte presentations are reminded that memoranda 
summarizing the presentations must (1) list all persons attending or otherwise participating in the meeting 
at which the ex parte presentation was made, and (2) summarize all data presented and arguments made 
during the presentation.  If the presentation consisted in whole or in part of the presentation of data or 
arguments already reflected in the presenter’s written comments, memoranda or other filings in the 
proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, 
memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or 
arguments can be found) in lieu of summarizing them in the memorandum.  Documents shown or given 
to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must 
be filed consistent with rule 1.1206(b).  In proceedings governed by rule 1.49(f) or for which the 
Commission has made available a method of electronic filing, written ex parte presentations or 
memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through 
213
 Assessment and Collection of Regulatory Fees for Fiscal Year 2017, Report and Order and Further Notice of 
Proposed Rulemaking, 32 FCC Rcd 7057, 7088, Appendix C (2017) (2017 Regulatory Fees Order); 2017 
Regulatory Fees Fact Sheet.
214
 47 U.S.C. § 159(b)(1)(B).
215
 The Commission annually reviews the regulatory fee schedule, proposes changes to the schedule to reflect 
changes in the amount of its appropriation, and proposes increases or decreases to the schedule of regulatory fees. 
2017 Regulatory Fees Order, 32 FCC Rcd at 7058.  The Commission allocates the total amount to be collected 
among the various regulatory fee categories.  Id. at 7059.  Thus, a change in the regulatory fee schedule applicable 
to one category may affect the regulatory fees applicable to other categories.
216
 Academic researchers from the Samuelson-Glushko Technology Law & Policy Clinic filed an ex parte letter 
stating that absent changes, the annual regulatory fee of $135,350 currently assessed to NGSO systems would 
effectively prevent universities seeking to deploy small satellite systems from utilizing the proposed licensing 
procedures, and asking that we seek comment on the regulatory fee in this Notice.  See Letter from Blake Reid, 
Director, et. al., Samuelson-Glushko Technology Law & Policy Clinic to Jose Albuquerque, Chief, Satellite 
Division, International Bureau, FCC, IB Docket No. 18-86 (filed Apr. 9, 2018).  Given the interdependency of the 
fees charged across individual categories, comments regarding regulatory fees should be filed in the proceedings for 
annual review of those fees, and there are no limitations that would hinder development of the record in those 
proceedings.
217
 47 CFR § 1.200(a).
Federal Communications Commission FCC 18-44
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the electronic comment filing system available for that proceeding, and must be filed in their native 
format (e.g., .doc, .xml, .ppt, searchable .pdf).  Participants in this proceeding should familiarize 
themselves with the Commission’s ex parte rules.
B. Comment Period and Procedures
80. Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, 
interested parties may file comments and reply comments on or before the dates indicated on the first 
page of this document.  Comments may be filed using the Commission’s Electronic Comment Filing 
System (ECFS).  See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Electronic Filers:  Comments may be filed electronically using the Internet by accessing the 
ECFS:  http://apps.fcc.gov/ecfs/.  
Paper Filers:  Parties who choose to file by paper must file an original and one copy of each 
filing.  If more than one docket or rulemaking number appears in the caption of this proceeding, 
filers must submit two additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
class or overnight U.S. Postal Service mail.  All filings must be addressed to the Commission’s 
Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary must be 
delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554.  
The filing hours are 8:00 a.m. to 7:00 p.m.   All hand deliveries must be held together with rubber 
bands or fasteners.  Any envelopes and boxes must be disposed of before entering the building.  
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must 
be sent to 9050 Junction Drive, Annapolis Junction, MD 20701.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street, 
SW, Washington DC  20554.
People with Disabilities:  To request materials in accessible formats for people with disabilities 
(braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the 
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
C. Initial Regulatory Flexibility Analysis
81. As required by the Regulatory Flexibility Act of 1980 (RFA),
218
 the Commission has 
prepared an Initial Regulatory Flexibility Analysis (IRFA) of the possible significant economic impact on 
small entities of the policies and rules proposed in the Notice of Proposed Rulemaking.  The analysis is 
found in Appendix B.  We request written public comment on the analysis.  Comments must be filed in 
accordance with the same deadlines as comments filed in response to the Notice and must have a separate 
and distinct heading designating them as responses to the IRFA.  The Commission’s Consumer and 
Governmental Affairs Bureau, Reference Information Center, will send a copy of this Notice, including 
the IRFA, to the Chief Counsel for Advocacy of the Small Business Administration.
D. Paperwork Reduction Act
82. This document contains proposed new and modified information collection requirements.  
If the Commission adopts any new or revised information collection requirement, the Commission will 
218
 See 5 U.S.C. § 603.
Federal Communications Commission FCC 18-44
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publish a separate notice in the Federal Register inviting the public to comment on the requirement, as 
required by the Paperwork Reduction Act of 1995, Public Law 104-13 (44 U.S.C. § 3501-3502).  In 
addition, pursuant to the Small Business Paperwork Reduction Act of 2002, Public Law 107-198, see 44 
U.S.C. § 3506(c)(4), we seek specific comment on how we might further reduce the information 
collection burden for small business concerns with fewer than 25 employees.
VII. ORDERING CLAUSES
83. Accordingly, IT IS ORDERED, pursuant to sections 4(i), 7, 8, 301, 303, 308, and 309 of 
the Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 157, 158, 301, 303, 308, 309, that 
this Notice of Proposed Rulemaking is ADOPTED.  
84. IT IS FURTHER ORDERED that the Commission’s Consumer and Governmental 
Affairs Bureau, Reference Information Center, SHALL SEND a copy of this Notice of Proposed 
Rulemaking, including the Initial Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy of 
the Small Business Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
Federal Communications Commission FCC 18-44
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APPENDIX A
Proposed Rules
For the reasons discussed above, the Federal Communications Commission proposes to amend Parts 2 
and 25 of Title 47 of the Code of Federal Regulations, as follows:
PART 2 – FREQUENCY ALLOCATIONS AND RADIO TREATY MATTERS: GENERAL 
RULES AND REGULATIONS
The authority citation for Part 2 continues to read as follows:
Authority: 47 U.S.C. 154, 302a, 303, and 336, unless otherwise noted.
1. Amend § 2.106, the Table of Frequency Allocations, as follows:
Under “UNITED STATES (US) FOOTNOTES,” add, in numerical order, footnote USXXX.
USXXX  In the bands 149.9-150.05 MHz and 1610.6-1613.8 MHz, small satellites as 
authorized under 47 CFR 25.122 operate as an application of the mobile-satellite 
service (Earth-to-space).
PART 25 – SATELLITE COMMUNICATIONS
The authority citation for Part 25 continues to read as follows:
Authority: Interprets or applies 47 U.S.C. 154, 301, 302, 303, 307, 309, 310, 319, 332, 605, and 721 
unless otherwise noted.
2. In § 25.113, revise paragraph (i) to read as follows:
§ 25.113 Station construction, deployment approval, and operation of spare satellites.
(i) An operator of NGSO space stations under a blanket license granted by the Commission, except for 
those authorized pursuant to the application process in § 25.122, need not apply for license modification 
to deploy and operate technically identical replacement satellites in an authorized orbit within the term of 
the system authorization. However, the licensee must notify the Commission of the intended launch at 
least 30 days in advance and certify that its operation of the additional space station(s) will not increase 
the number of space stations providing service above the maximum number specified in the license.
3. In § 25.114, revise paragraph (d) to read as follows:
§ 25.114 Applications for space station authorizations.
* * * * *
(d)  The following information in narrative form shall be contained in each application, except NGSO 
space station applications filed pursuant to § 25.122:
* * * * *
4. In § 25.117, revise paragraph (d)(1) to read as follows:
§ 25.117 Modification of station license.
* * * * * 
(d)(1) Except as set forth in § 25.118(e) and (f), applications for modifications of space station 
authorizations shall be filed in accordance with § 25.114 and/or § 25.122, as applicable, but only those 
Federal Communications Commission FCC 18-44
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items of information listed in § 25.114 and/or § 25.122 that change need to be submitted, provided the 
applicant certifies that the remaining information has not changed.
* * * * *
5.  In § 25.121, revise paragraphs (a)(1) and add paragraph (a)(3) to read as follows:
§ 25.121 License term and renewals.
(a) * * *
    (1) Except for licenses for DBS space stations, SDARS space stations and terrestrial repeaters, 17/24 
GHz BSS space stations licensed as broadcast facilities, and licenses for which the application was filed 
pursuant to § 25.122, licenses for facilities governed by this part will be issued for a period of 15 years.
* * * * *
   (3) Licenses for which the application was filed pursuant to § 25.122 will be issued for a period of 5 
years, without the possibility of extension or replacement authorization.  
* * * * *
6.   Add § 25.122, to read as follows:
§ 25.122 Applications for streamlined small satellite authorization.
(a)  This Section shall only apply to applicants for NGSO satellite systems that are able to certify 
compliance with the certifications set forth in paragraph (c) of this section.  For applicants seeking to be 
authorized under this section, a comprehensive proposal for Commission evaluation must be submitted 
for each satellite in the proposed NGSO satellite system on FCC Form 312, Main Form and Schedule S, 
as described in § 25.114(a)-(c), together with the certifications described in paragraph (c) of this section 
and the narrative requirements described in paragraph (d) of this section.  
(b)  Applications for NGSO satellite systems may be filed under this section, provided that the total 
number of space stations in the system is ten or fewer.
(1) To the extent that space stations in the satellite system will be technically-identical, the 
applicant may submit an application for blanket-licensed space stations.
(2) Where the space stations in the satellite system are not technically-identical, the applicant 
must certify that each type of space station satisfies the criteria in paragraph (c) of this section, 
and submit technical information for each type of space station.
(c) Certifications under this section.  Applicants filing for licenses under the streamlined procedure 
described in this section must include with their applications certifications that the following criteria will 
be met for all space stations to be operated under the license:
(1)  The space station(s) will operate only in non-geostationary orbit;
(2)  The total on-orbit lifetime is planned to be five years or less for the system;
(3)  The space station(s):
(i) Will be deployed at an orbital altitude of 400 km or below;
(ii) Will be deployed from the International Space Station, or a vehicle docked with the 
International Space Station; or
(iv) Will maintain a propulsion system and have the ability to make collision avoidance 
maneuvers at any time the space station is located above an altitude of 400 km.
(4) The space station(s) will be identifiable by unique markers distinguishing it from other space 
stations or space objects;
(5) The space station(s) will release no operational debris;
Federal Communications Commission FCC 18-44
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(6) No debris will be generated in an accidental explosion resulting from the conversion of energy 
sources on board the space station into energy that fragments the spacecraft;
(7) The probability of a collision between each space station and any other large object during the 
orbital lifetime of the space station is less than 0.001.
(8) The space station(s) will be disposed of post-mission through atmospheric re-entry.  The 
probability of human casualty from portions of the spacecraft surviving re-entry and reaching the 
surface of the Earth is zero based on reasonable calculations; 
(9) Operation of the space station(s) will not cause harmful interference to space stations 
currently authorized under this part and operating in the requested frequency band(s) consistent 
with the U.S. Table of Frequency Allocations.  Operations will not unreasonably preclude future 
entrants from utilizing the requested frequency band(s); 
(10) The space station(s) will not transmit unless it receives a command originating from the 
ground to do so and can be commanded by command originating from the ground to cease 
transmissions;
(11) Each space station will have physical dimensions greater than 10 cm x 10 cm x 10 cm; and 
(12) Each space station will have a mass of 180 kg or less.
 (d) Other application information. The following information in narrative form shall be contained in each 
application:
(1) An overall description of system facilities, operations, and services and an explanation of how 
uplink frequency bands would be connected to downlink frequency bands; 
(2) Public interest considerations in support of grant; 
(3) A description of means by which requested spectrum could be shared with both current and 
future operators, (e.g., how ephemeris data will be shared, antenna design, earth station 
geographic locations) thereby not unreasonably precluding other operations in the requested 
frequency band(s);
 (4) For space stations with any means of maneuverability, including both active and passive 
means, a description of the design and operation of maneuverability and de-orbit systems; and
(5) If at the time of application any manned spacecraft is located at or below the deployment 
orbital altitude of the space station seeking a license, a description of the design and operational 
strategies that will be used to avoid in-orbit collision with such manned spacecraft.
7. In § 25.156, revise paragraph (d)(1) to read as follows:
§ 25.156 Consideration of applications
* * * * *
(d)(1) Applications for NGSO-like satellite operation will be considered pursuant to the procedures set 
forth in § 25.157, except as provided in § 25.157(b) or § 25.157(i), as appropriate.
* * * * *
8. In § 25.157, revise paragraph (a), and add paragraph (i) to read as follows:
§ 25.157 Consideration of applications for NGSO-like satellite operation.
(a)  This section specifies the procedures for considering license applications for “NGSO-like” satellite 
operation, except as provided in paragraphs (b) and (i) of this section.  For purposes of this section, the 
term “NGSO-like satellite operation” means:
(1) Operation of any NGSO satellite system, and
Federal Communications Commission FCC 18-44
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(2) Operation of a GSO MSS satellite to communicate with earth stations with non-directional 
antennas.
* * * * *
(i) For consideration of license applications filed pursuant to the procedures described in § 25.122, the 
application will be processed and granted in accordance with §§ 25.150-25.156, taking into consideration 
the information provided by the applicant under § 25.122(d)(3), but without a processing round as 
described in this section and without a queue as described in § 25.158.
9. In § 25.159, revise paragraph (b) to read as follows:
§ 25.159 Limits on pending applications and unbuilt satellite systems.
* * * * *
(b)  Applicants with an application for one NGSO-like satellite system license on file with the 
Commission in a particular frequency band, or one licensed-but-unbuilt NGSO-like satellite system in a 
particular frequency band, will not be permitted to apply for another NGSO-like satellite system license in 
that frequency band, except for applicants filing pursuant to § 25.122.
* * * * *
10.  In § 25.165, revise paragraphs (a) and (e), and add paragraph (h) to read as follows:
§ 25.165 Surety bonds.
 (a)  For all space station licenses issued after September 20, 2004, other than licenses for DBS space 
stations, SDARS space stations, space stations licensed under the process outlined in section 25.122, and 
replacement space stations as defined in paragraph (e) of this section, the licensee must post a bond within 
30 days of the grant of its license. Failure to post a bond will render the license null and void 
automatically.
* * * * *
(e) A replacement space station is one that:
(1) Is authorized to operate at an orbital location within ±0.15° of the assigned location of a GSO 
space station to be replaced or is authorized for NGSO operation and will replace an existing 
NGSO space station in its authorized orbit, except for space stations authorized under section 
25.122;
(2) Is authorized to operate in the same frequency bands, and with the same coverage area as the 
space station to be replaced; and
(3) Is scheduled to be launched so that it will be brought into use at approximately the same time, 
but no later than, as the existing space station is retired.
* * * * *
(h)  Licensees of space stations under the process outlined in section 25.122 need not post a bond unless 
the space station is not launched, orbiting, and operational, as described in § 25.164, within a period of 
one year plus 30 days following grant of license.  If the space station is not operational following the one 
years plus 30 days period, then the licensee must file a bond in accordance with paragraph (a)(1) of this 
Section, and be subject to the requirements of paragraphs (b), (c), and (g) of this section.
* * * * *
Federal Communications Commission FCC 18-44
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11. In § 25.217 of the Commission’s rules, revise paragraph (b)(1) as follows:
§ 25.217 Default service rules.
(b)(1) For all NGSO-like satellite licenses, except as specified in paragraph (b)(4), for which the 
application was filed pursuant to the procedures set forth in § 25.157 after August 27, 2003, authorizing 
operations in a frequency band for which the Commission has not adopted frequency band-specific 
service rules at the time the license is granted, the licensee will be required to comply with the following 
technical requirements, notwithstanding the frequency bands specified in these rule provisions: §§ 
25.143(b)(2)(ii) (except NGSO FSS systems) and (iii), 25.204(e), and 25.210(f) and (i).
* * * * *
(4) For all small satellite licensees, for which the application was filed pursuant to § 25.122, 
authorizing operations in a frequency band for which the Commission has not adopted frequency-band 
specific service rules at the time the license is granted, the licensee will not be required to comply with 
the technical requirements specified in this section.
* * * * *
Federal Communications Commission FCC 18-44
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APPENDIX B
Initial Regulatory Flexibility Analysis
As required by the Regulatory Flexibility Act of 1980, as amended (RFA),
1
 the Commission has prepared 
this present Initial Regulatory Flexibility Analysis (IRFA) of the possible significant economic impact on 
a substantial number of small entities by the policies and rules proposed in this Notice of Proposed 
Rulemaking (NPRM).  Written public comments are requested on this IRFA.  Comments must be 
identified as responses to the IRFA and must be filed by the deadlines specified in the NPRM for 
comments. The Commission will send a copy of this NPRM, including this IRFA, to the Chief Counsel 
for Advocacy of the Small Business Administration (SBA).
2
  In addition, the NPRM and IRFA (or 
summaries thereof) will be published in the Federal Register.
3
 
A. Need for, and Objectives of, the Proposed Rules
This NPRM seeks comment on several proposals relating to the Commission’s rules and policies related 
to small satellites. The rules proposed in this Notice will accommodate authorization under Part 25 of the 
Commission’s rules of satellites that until now have been licensed through the experimental licensing 
process in Part 5 of the Commission’s rules and have not been able to provide full commercial service, or 
have been required to file for a regular Part 25 NGSO authorization. Adoption of the proposed changes 
would modify 47 CFR Part 25 of the Commission’s rules to make small satellite authorization more 
accessible, limit regulatory costs borne by applicants, shorten application processing times, and offer 
protection for critical communication links, while promoting efficient use of spectrum.
B. Legal Basis
The proposed action is authorized under sections 4(i), 7, 8, 301, 303, 308 and 309 of the Communications 
Act of 1934, as amended, 47 U.S.C. §§ 154(i), 157, 158, 301, 303, 308, 309.
C. Description and Estimate of the Number of Small Entities to Which the Proposed 
Rules Will Apply
The RFA directs agencies to provide a description of, and, where feasible, an estimate of, the number of 
small entities that may be affected the proposed rules, if adopted.
4
  The RFA generally defines the term 
“small entity” as having the same meaning as the terms “small business,” “small organization,” and 
“small governmental jurisdiction.”
5
  In addition, the term “small business” has the same meaning as the 
term “small business concern” under the Small Business Act.
6
  A “small business concern” is one which:  
(1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any 
additional criteria established by the Small Business Administration (SBA).
7
  
1
 See 5 U.S.C. § 603.  The RFA, see 5 U.S.C. §§ 601-612, has been amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996, (SBREFA) Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2
 See 5 U.S.C. § 603(a).
3
 See 5 U.S.C. § 603(a).
4
 5 U.S.C. § 604(a)(3).
5
 5 U.S.C. § 601(6).
6
 5 U.S.C. § 601(3) (incorporating by reference the definition of “small business concern” in 15 U.S.C. § 632).  
Pursuant to the RFA, the statutory definition of a small business applies “unless an agency, after consultation with 
the Office of Advocacy of the Small Business Administration and after opportunity for public comment, establishes 
one or more definitions of such term which are appropriate to the activities of the agency and publishes such 
definition(s) in the Federal Register.”  5 U.S.C. § 601(3).
7
 Small Business Act, 15 U.S.C. § 632 (1996).
Federal Communications Commission FCC 18-44
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Satellite Telecommunications and All Other Telecommunications
The rules proposed in this Notice would affect some providers of satellite telecommunications services, if 
adopted.  Satellite telecommunications service providers include satellite and earth station operators. 
Since 2007, the SBA has recognized two census categories for satellite telecommunications firms: 
“Satellite Telecommunications” and “All Other Telecommunications.”  Under both categories, a business 
is considered small if it had $32.5 million or less in average annual receipts.
8
The first category of Satellite Telecommunications “comprises establishments primarily engaged in 
providing telecommunications services to other establishments in the telecommunications and 
broadcasting industries by forwarding and receiving communications signals via a system of satellites or 
reselling satellite telecommunications.”
9
  For this category, Census Bureau data for 2012 show that there 
were a total of 333 satellite telecommunications firms that operated for the entire year.
10
  Of this total, 299 
firms had annual receipts of under $25 million, and 12 firms had receipts of $25 million to $49,999,999.
11
The second category of Other Telecommunications is comprised of entities “primarily engaged in 
providing specialized telecommunications services, such as satellite tracking, communications telemetry, 
and radar station operation. This industry also includes establishments primarily engaged in providing 
satellite terminal stations and associated facilities connected with one or more terrestrial systems and 
capable of transmitting telecommunications to, and receiving telecommunications from, satellite systems.  
Establishments providing Internet services or voice over Internet protocol (VoIP) services via client-
supplied telecommunications connections are also included in this industry.”
12
  For this category, Census 
Bureau data for 2012 show that there were a total of 1,442 firms that operated for the entire year.
13
  Of 
this total, 1,415 firms had annual receipts of under $25 million.
14
  We anticipate that some of these “Other 
Telecommunications firms,” which are small entities, are earth station applicants/licensees, but since we 
do not propose changes to our licensing rules specific to earth station, we do not anticipate that these 
entities would be affected if our proposed rule changes are adopted.
We anticipate that our proposed rule changes may have an impact on space station applicants and 
licensees.  While traditionally space station applicants and licensees only rarely qualified under the 
definition of a small entity, the small satellite applicants and licensees that are contemplated by this 
Notice may qualify as small entities that would be affected by our proposed actions.
D. Description of Projected Reporting, Recordkeeping, and Other Compliance 
Requirements for Small Entities
This NPRM seeks comments and proposed several rule changes that will affect small satellite 
authorization procedures, recordkeeping, and other compliance requirements for space station operators.  
Many of the proposed changes, as described below, would decrease the burden in various regards for 
entities that plan to launch or operate satellites that may be colloquially referred to as “small satellites.” 
First, this NPRM proposes to simplify application requirements by tailoring a section specifically for 
small satellites or small satellite constellations meeting certain characteristics, such as low total number of 
satellites, short mission duration, and low altitude orbit.  These proposals include some documentation 
requirements consistent with those already established for an applicant under Part 25 of the Commission’s 
8
 See 13 C.F.R. § 121.201 NAICS code 517410 and code 517919. 
9
 U.S. Census Bureau, 2007 NAICS Definitions, “517410 Satellite Telecommunications”.
10
 See https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk.
11
 Id.
12
 U.S. Census Bureau, 2007 NAICS Definitions, “517919 Satellite Telecommunications”.
13
 See 13 C.F.R. § 121.201, NAICS code 517919.
14
 https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk.
Federal Communications Commission FCC 18-44
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rules.  We propose that some of the informational requirements, however, may be completed by a 
certification rather than narrative description, which we believe will lessen the burden on these small 
satellite applicants.  
Second, this NPRM proposes to identify frequencies which may be useful for small satellites. This portion 
of the NPRM should not increase any requirements with respect to small entities, but instead, is designed 
to help small entities apply for satellite licenses.
Third, this NPRM proposes to decrease the application fees applicable to small satellites to $30,000.
In sum, this NPRM seeks to make obtaining authorization of small satellites more accessible, limit 
regulatory costs borne by applicants, shorten application processing times, and encourage the protection 
of communications links, while enabling efficient use of spectrum.
E. Steps Taken to Minimize Significant Economic Impact on Small Entities, and 
Significant Alternatives Considered
The RFA requires an agency to describe any significant, specifically small business, alternatives that it 
has considered in reaching its proposed approach, which may include the following four alternatives 
(among others): “(1) the establishment of differing compliance or reporting requirements or timetables 
that take into account the resources available to small entities; (2) the clarification, consolidation, or 
simplification of compliance and reporting requirements under the rules for such small entities; (3) the 
use of performance rather than design standards; and (4) an exemption from coverage of the rule, or any 
part thereof, for such small entities.”
15
This NPRM seeks comment from all interested parties.  The Commission is aware that some of the 
proposals under consideration may impact small entities.  Small entities are encouraged to bring to the 
Commission’s attention any specific concerns they may have with the proposals outlined in this NPRM. 
The Commission expects to consider any economic impact on small entities, as identified in comments 
filed in response to this NPRM, in reaching its final conclusions and taking action in this proceeding.
In this NPRM, the Commission considers rule revisions to reflect changes and advances in the satellite 
industry.  This NPRM proposes to eliminate some information filing requirements.  We propose that 
applicants may provide certifications in lieu of narrative information.  In addition, we propose that 
applicants be exempt from the bond requirement for a certain period of time, and that applications for 
small satellites will not be subject to the processing round procedures.  These proposals are designed to 
lower the regulatory burden involved in licensing small satellites and reduce application processing times, 
thereby lessening the burden of compliance on small entities with more limited resources than larger 
entities.  Additionally, the NPRM proposes to decrease the application fee for small satellite applicants.
The proposed streamlined process is optional, so a small satellite applicant could still choose to apply 
under the Commission’s existing Part 5 or Part 25 rules.  The proposed changes, however, would 
facilitate authorization of small satellites under Part 25 of the Commission’s rules.  These changes could 
support smaller entities who aim to develop and launch a small satellite or a small satellite constellation. 
F. Federal Rules that May Duplicate, Overlap, or Conflict with the Proposed Rules
None.
15
 5 U.S.C. § 603(c)(1)-(c)(4).
Federal Communications Commission FCC 18-44
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STATEMENT OF
CHAIRMAN AJIT PAI
Re: Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86.
A few weeks ago, I had the chance to visit Launchpad 39A at the Kennedy Space Center in Cape 
Canaveral, Florida.  That’s where numerous historic space missions launched—including Apollo 11, 
which sent the first humans to the moon, and Apollo 13, the “successful failure” which set a record for the 
farthest distance humans ever traveled from Earth.  It’s a testament to human ingenuity that since those 
missions, we have expanded the variety and increased the quantity of objects launched into space, 
including recently a car.  
In recent years, for example, smaller, less-expensive satellites with short-duration missions—
often known as “small satellites”—that are often used for scientific research by universities, and 
increasingly for commercial operations, have also been developed and launched into space.  Their 
numbers have grown, and with them a problem: more satellites mean more regulatory reviews, but our 
current rules weren’t designed with these smaller satellites in mind.
Today, we begin the process for solving this problem.  We aim to streamline the process for 
authorizing commercial small-satellite operations.  If operators want to launch satellites with certain 
characteristics, such as short orbital lifetimes, they could choose to file under a new, alternative small 
satellite process.  These procedures would be less burdensome while still preserving FCC interests in 
issues like efficient spectrum use and limiting orbital debris.  We also ask a number of questions, 
including about application fees, that will inform our decision-making as we consider implementing this 
new process.
This is yet another measure the FCC is taking to address one of its own continuing missions: 
encouraging innovation through next-generation technologies.  Easing the regulatory burdens for new 
space missions and research using small satellites will ultimately benefit everyone from academic 
researchers to small businesses.
Thank you to the dedicated staff who worked on this item: Jose Albuquerque, Christopher Bair, 
Stephen Duall, Jennifer Gilsenan, Karl Kensinger, Daudeline Meme, Sankar Persaud, Tom Sullivan, Troy 
Tanner, and Merissa Velez from the International Bureau; Patrick Forster, Michael Ha, Nicholas Oros, 
Jamison Prime, and Ron Repasi from the Office of Engineering and Technology; Scot Stone from the 
Wireless Telecommunications Bureau; Roland Helvajian from the Office of Managing Director; and 
Deborah Broderson, David Horowitz, and Andrea Kelly from the Office of General Counsel.
Federal Communications Commission FCC 18-44
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STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
Re: Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86.
Great things come in small packages!  The first time those of us of a certain height attached real 
meaning to this phrase, came on the heels of being consoled after being made to feel exceptionally small 
and inadequate, from the words or hands of a playground bully.
Today, however, this oft-recited phrase can be used to describe several trends taking place in the 
technology and communications industries.  The first commercial cellphone was literally the size of a 
brick.  Today’s smart phones fit in our back pockets.  In the 1960s and 70s, you needed a room the size of 
a huge office to house that generation’s super computer.  Now, those smart phones in our purses contain 
more computing power than all at NASA back in 1969.
A few years back, researchers at the University of Illinois developed batteries only a few 
millimeters in size and they can be used to jump-start a car, and so long as consumers continue to demand 
portability when it comes to their electronic devices, and as long as there are engineers working on 
satisfying that demand, we should expect the trend towards smaller device sizes to continue.
This shrinking trend when it comes to our technology devices, is now impacting the satellite 
industry.  “Small satellites” are being deployed into orbit efficiently and cost-effectively for a variety of 
uses.  We are seeing rising numbers of holders of experimental and amateur licenses for small satellite 
systems, seek authorization of those systems for commercial use.  The Earth imagery and other 
information from these systems are being used by the tech industry to develop big data technologies for a 
variety of applications.  One such application is in the field of agriculture, where satellite and other data is 
being used to improve crop yields.  Small satellite systems are also being used for space in cloud data and 
analytics providing advanced maritime, aviation, and weather tracking.
Today, the Commission rightly acknowledges this trend in the commercial industry and proposes 
new licensing procedures that should facilitate greater investment and innovation.  Providing for one 
streamlined set of procedures, and seeking comment on how we can tailor our Part 25 license and service 
rules for small satellite systems, means that we are off to a great start.  I am in full support of today’s item 
and thank Tom Sullivan and the International Bureau for an impressive Notice of Proposed Rulemaking.
Federal Communications Commission FCC 18-44
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STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY
Re: Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86.
I approve of today’s notice that should promote innovation and entrepreneurship by facilitating 
and streamlining the launch of small satellites, such as CubeSats.  Over the past year, the Commission has 
witnessed impressive advancements in satellite technologies.  From NGSO constellations and next-
generation geos, to impressive space launch capabilities, we are witnessing the proliferation of systems 
providing faster broadband speeds, engaging in earth observation, and pushing the envelope of scientific 
research.  Hopefully, this proceeding will lead to future inventions and services that we cannot envision 
today.
This item’s focus on smaller systems and shorter-term projects should promote such research and 
development, along with the marketing of new services.  As proposed, the streamlined processes would 
be available for applications involving ten or fewer satellites with a life cycle of five years or less.  As we 
go forward, we must be clear about which entities will be able to utilize these streamlined procedures and 
be careful that we do not create unintentional loopholes that could give some entities a competitive 
advantage over others. 
Further, with this proceeding comes added responsibilities.  We must ensure that the increased 
use of small sats does not cause harmful interference to other services.  This an issue we have been faced 
with and have not adequately resolved in the context of NGSOs and in-line interference.  
As I have discussed before, we also need a better plan to address orbital debris and dead satellites 
so that we do not clutter space with such things as used rocket parts.  Therefore, we must make certain 
that these small sats will not cause damage to other satellites and that they de-orbit appropriately at the 
end of life.
Generally, the Commission must consider orbital debris when contemplating satellite rules going 
forward.  Other federal agencies are working on best practices, and industry and governments are working 
on ways to clean up space, including such ideas as launching nets and harpoons to snag pieces of space 
trash as they fly by.
1
  It is estimated that there may be more than 650,000 objects larger than a fingernail 
and 170 million pieces larger than one millimeter.
2
  This may not sound like much to some, but these 
objects can travel at speeds of up to 17,500 miles per hour, causing quite a bit of damage.  While the FCC 
should not be regulating space debris, it should engage on this issue and do its part to ensure that its 
licensees are responsible stewards of the orbits surrounding the Earth.  We certainly should ensure that we 
do not add to the problem.  I look forward to discussing this issue with industry and other federal agencies 
in the coming months.
1
 Stephen Clark, Eliminating Space Junk Could Take Step Toward Reality with Station Cargo Launch, SPACEFLIGHT 
NOW, Apr. 1, 2018, https://spaceflightnow.com/2018/04/01/eliminating-space-junk-could-take-step-toward-reality-
with-station-cargo-launch/. 
2
 Dave Mosher and Samantha Lee, More than 14,000 Hunks of Dangerous Space Junk are Hurtling Around Earth – 
Here’s Who Put it All Up There, BUSINESS INSIDER, Mar. 29, 2018, 
http://markets.businessinsider.com/news/stocks/space-junk-debris-amount-statistics-countries-2018-3-1019848316  
(adding that the Space Surveillance Network tracks 23,000 objects larger than a softball and that 14,000 of these are 
uncontrolled).
Federal Communications Commission FCC 18-44
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STATEMENT OF
COMMISSIONER BRENDAN CARR
Re: Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86.
Both on the ground and beyond Earth’s atmosphere, wireless technology is getting smaller.  On 
the terrestrial side, upwards of 80% of new deployments are small cells.  And we’re seeing a similar trend 
in space—smaller, less expensive satellites are being deployed in increasing numbers.  In fact, the U.S. 
now leads the world in small sat launches.  Americans stand to benefit from these commercial 
deployments with use cases ranging from the Internet of Things to smart agriculture applications.
As policymakers, we need to make sure our rules keep pace with these changes in technology.  
And that means ensuring that our regulations are “right sized” and tailored to reflect the costs and impacts 
of these innovations. 
Last month, the FCC recognized this principle when we voted to exempt small wireless facilities 
from regulatory procedures designed for large towers.  The record showed that, by subjecting small cells 
to large scale regulations, we were discouraging broadband deployment in those communities that need it 
most and threatening to undermine the United States’ efforts to win the global race to 5G.
In this Notice, we recognize that the same problem could exist for small satellites.  While our 
traditional Part 25 approach for processing satellite applications involves legal, technical, and other 
showings that may make sense for large satellites or significant constellations, the regulatory costs 
associated with these reviews can prevent the business case for small sats from getting off the ground.  So 
I am glad we are now proposing to define a new category of small sats and seeking comment on 
streamlined approval procedures.  This step should encourage investment and innovation in small sats 
while continuing to promote our interests in limiting orbital debris and protecting against harmful 
interference.  
An oversized regulatory burden should never be what stands in the way of progress, so I am 
pleased to support this proposal.  I want to thank the staffs of the International Bureau and the Wireless 
Telecommunications Bureau for their work on this item.
Federal Communications Commission FCC 18-44
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STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL
Re: Streamlining Licensing Procedures for Small Satellites, IB Docket No. 18-86.
Welcome to the second space age.  During the first, which began with the end of the Second 
World War, space missions depended on the prowess of our superpowers.  This was for good reason—
going to space was out-of-this world expensive.  Missions were awe-inspiring but rare.  But this new 
space age is different.  It relies on radically new technologies and business models.  It features a much 
wider range of space interests and actors.  Satellites are smaller, crowd-funded constellations are possible, 
and space tourism is no longer simply a dream.  In short, we have so many more reasons to reach for the 
stars.  
So today we take steps to tailor our licensing framework for this new era.  That’s important.  
Across the board, we need to do more to prepare for the proliferation of satellites headed to higher 
altitudes.  To this end, in this rulemaking we seek comment on an alternative application process for small 
satellites, ask questions about on-orbit lifetime, and explore issues of maneuverability and trackability.  
We also seek comment on new frequencies for new constellations of small satellites.    
I look forward to the record that develops.  But to be truly prepared for the second space age I 
think there are two additional issues that deserve our attention now.
First, the FCC needs to tackle the growing challenge of orbital debris.  At present, the risk of 
debris-generating collisions is reasonably low.  Still, some satellite collisions have happened.  As more 
actors participate in the space industry with larger satellite constellations, the frequency of these accidents 
is going to increase.  Unchecked, growing debris in orbit could make some regions of space unusable for 
decades to come.  That’s not an acceptable outcome.  It’s why we need—right now—to develop a 
comprehensive policy to mitigate collision risks and ensure space sustainability.
Second, the FCC needs to coordinate more closely with other federal authorities to figure out just 
what our national policies are for this jumble of new space activity.  Right now, the National Space 
Council is considering policy changes to help promote the growth of the commercial space industry.  
Their efforts encompass everything from streamlining licenses to reforming export controls to protecting 
airwaves facilitating space activities.  Its membership spans the civil, military, and commercial sectors, 
including the Secretary of State, Secretary of Defense, Secretary of Transportation, Secretary of 
Homeland Security, and Director of National Intelligence.  Representatives from the Office of 
Management and Budget, National Aeronautics and Space Administration, and the Joint Chiefs of Staff, 
among others, also serve on this council.  It’s an impressive list.  But the FCC should have a seat at this 
table.  It’s a glaring omission that the agency does not because through our oversight of the airwaves and 
licensing of satellite services we have an important role ensuring the viability of space for future 
generations.  Cutting the FCC out of this discussion is an unseemly mistake—and one that deserves a fix.