Space Application Processing Shot Clocks Lack Clear Consensus

Pointing to shot clocks in wireless infrastructure decisions, SpaceX said that they "not only promote[s] faster broadband deployment, but also provide[s] an essential catalyst for more efficient application processing." It urged a 180-day shot clock for all satellite and earth station applications. SpaceX said that since 2021, 49% of satellite applications -- 152 of 308 -- were modifications and 60 of those 152 are pending in part. It said 30% of earth station applications -- 444 of 1,411 -- were modifications, with 107 of those applications pending. However, many modifications are small changes that pose no increased risk of harmful interference or risk to space sustainability, it said. SpaceX said the agency could address some of that logjam by making clear that satellite modifications that increase transmission capacity, improve spectral efficiency and don't substantially modify the satellite as authorized can be done without prior FCC approval. The agency similarly should allow more earth station upgrades without prior authorization, it said.

With clear and unambiguous timelines by which applications will be processed, satellite operators can then ensure their applications are filed on a timely basis, which helps reduce constraints on FCC resources, Spire Global said. It said expanding the minor modification rule regarding changes that don't increase the risk of harmful interference would better reflect "the heterogeneity of [non-geostationary orbit] constellations."

While backing many FCC proposals in the FNPRM, including allowing removal of a satellite point of communication and modification of an earth station antenna identification without prior authorization, Viasat said the FCC should avoid shot clocks on application decisions and keep current procedures for operators pursuing extensions of special temporary (STA) requests. Shot clocks "risk undermining the quality of the Commission’s decision-making process by forcing it to rush to judgment," it said.

"A shot clock applicable to all space and earth station applications may result in decisions influenced by time constraints rather than merit alone," Intelsat echoed. It said allowing a limited license for earth stations without an identified satellite point of communication adds steps to the application process rather than streamlining. Adopting shot clocks is premature before the FCC has fully resourced the Space Bureau, said SES/O3b.

The Satellite Industry Association also backed allowing removal of satellite points of communication and changes to antenna identification without prior notification to the FCC. It supported eliminating the 60-day filling window for earth station and NGSO satellite renewals, replacing it with a window that allows filing the license renewal request within 12 months before expiration. It pushed back on the FCC-floated idea of earth stations obtaining a limited license without a communication point. Not allowing that station to operate until a point of communication is added wouldn't give operators more flexibility but instead would bifurcate the application process, SIA said.

Minor earth station antenna modifications without having to notify the FCC beforehand would let satellite operators "be responsive to customer demand or unforeseen technical issues in a timely manner," Myriota said. Given that it can be tough to execute a full regulatory mission under a shot clock, it said that clocks should apply not to license issuance but to posting an application on public notice, or for any subsequent, substantive questions the agency may have after the public notice period is concluded.

Urging creation of the equivalent of special temporary authorization for companies with U.S. market access, Eutelsat/OneWeb said such a "special temporary market access" process should mirror the STA process for U.S.-flagged operators. Others backing an expanded STA process for market access applicants included Spire and Myriota. Iridium said the FCC should exercise caution before changing the processing procedures for earth station applications that involve the use of shared bands for which coordination is required.

Coordination requirements regarding applications seeking to add new points of communication to an existing earth station authorization in certain government-shared bands often duplicate already-completed work and make it difficult for ground stations as a service providers to serve new customers, Microsoft said. Amazon Web Services said the earth station coordination process could be made more efficient in situations where satellite downlinks have already been coordinated with federal users by not requiring coordination again on the side of the earth station operator. It backed clocks for providing a satellite or earth station application to NTIA for federal coordination.