FCC Publishes NPRM Proposing to Modernize Space and Earth Station Licensing Processes in Federal Register

On October 29, 2025, the FCC released the adopted Notice of Proposed Rulemaking (“NPRM”) proposing to streamline space and earth station licensing under a new Part 100 of the FCC’s rules, replacing the existing Part 25.  This item was adopted at the October Open Meeting.  Notably, in the adopted item, the FCC replaced the earth station “Nationwide Blanket License” terminology used in the draft item with “Nationwide, Non-Site License.”

Modernization of Earth Station Licensing

The NPRM’s proposals related to earth station licensing are largely aimed at replacing the existing site-by-site process with a two-step blanket licensing and registration framework.  This proposed process is designed to enhance efficiency while maintaining robust interference protections.  Over time, the FCC envisions that this framework will evolve into an automated, data-driven registration and coordination system, similar to that used in higher frequency bands (e.g., 70/80/90 GHz).

This proposal responds to industry concerns that the current earth station licensing process is overly burdensome and unworkable for large-scale satellite networks.  The NPRM’s proposals include:

• New “Immovable Earth Stations” Category: The Commission proposes establishing a new category, “Immovable Earth Stations,” defined as “[a]n earth station licensed under either a blanket license or a single location authorization that is located at a single fixed location that must be registered and coordinated before operating.”  This is intended to distinguish the FCC’s definition of fixed earth station (which operate in the Fixed-Satellite Service or “FSS”) from other types of earth stations.
• Nationwide Blanket Licensing and Site Registration for “Immovable Earth Stations”: Operators would first obtain a single nationwide blanket license and then register individual earth station sites before commencing operations, rather than filing a full application for each site.  Only applicants who do not require any exceptions or waivers would be permitted to apply for a blanket license for Immovable Earth Stations and then register locations (they could also opt to utilize the site-by-site process).
• Coordination and Waivers: Licensees requiring waivers or exceptions would still need to file site-specific applications, and all registered sites would require proof of completed coordination prior to operation.
• Simplified Applications: Applicants would continue to file FCC Form 312 – Main Form and Schedule B initially but could later certify to no changes for additional authorizations rather than refiling the entire form.  Additional specific information may be submitted based upon the type of application (e.g., rather than applying radiofrequency exposure requirements to all applicants, the FCC proposes to only require such information for user terminal and Earth Stations in Motion applications).  The NPRM further seeks comment on the type of necessary information that should be required.
• Expanded Disclosure Requirements: The FCC proposes codifying existing space station management and ownership disclosure rules and expanding them to all applicants filing Form 312, including earth station applicants.
• Revised Market Access Rules: The FCC proposes to prohibit U.S. market access through earth station licensing and seeks comment on whether to bar foreign registrants under the Registration Convention from receiving separate U.S. authorizations.

Procedural and Processing Reforms

The NPRM also proposes significant procedural updates to further streamline license processing and ensure consistency across services.  Specifically, the FCC proposes to:

• Processing and Timelines: Establish standardized processing timelines, completeness standards, public comment procedures, and rules for information requests to applicants, mirroring the new space station process.  This would include but not be limited to, FCC shot-clocks for processing (30 days from submission/fee payment); expedited and regular Public Notice timelines (7-day and 15-day, respectively).
• Conditional Authority:  Applications that conform to the FCC’s rules would be permitted to begin temporary pre-grant operations on a non-interference, unprotected basis once the application is placed on public notice, similar to the current process for Special Temporary Authority (“STA”).  Applications that do not conform with the Commission’s rules—for example, if they request a waiver or do not certify in the affirmative to requested certifications—will not be afforded this status.
• STA Reform: Limit STAs to two types, 60-day and 180-day, restrict extensions, and deem 60-day STAs granted upon filing and fee payment, reducing delays.
• License Terms: Extend the license term for most earth stations to 20 years, providing consistency and predictability for operators communicating with multiple satellites.
• Construction Period: Require Immovable Earth Stations to begin operations within 365 days of site registration to prevent spectrum warehousing and ensure efficient spectrum use.

Technical and Coordination Standards

While the FCC does not propose major changes to core technical operating criteria, it seeks to simplify and generalize standards to improve consistency and reduce redundancy.  Specifically, the NPRM proposes to:

• Simplified Antenna Performance Standards: Consolidate multiple band-specific standards into a single set of antenna gain and polarization requirements applicable across frequency bands.
• Unified Digital/Analog Standard: Adopt a single transmission standard for both digital and analog communications.
• New Non-Geostationary Orbit (“NGSO”) Off-Axis EIRP Limits: Introduce off-axis EIRP density limits for NGSO FSS earth stations, including feeder links, to reduce interference.
• Streamlined Geostationary Orbit (“GSO”) EIRP Rules: Establish a single GSO off-axis EIRP limit covering all bands, replacing the current fragmented approach.
• Clarified Coordination Requirements: Codify and clarify coordination obligations between earth station operators to mitigate interference risks.
• Frequency Table Simplification: Remove the redundant list of available frequency bands, already reflected in the U.S. Table of Frequency Allocations, to avoid confusion and misinterpretation.

The FCC acknowledges that the proposed blanket licensing and registration framework may not apply uniformly across all frequency bands, particularly those involving shared or mixed-use spectrum (e.g., C-band, UMFUS).  Nevertheless, it tentatively concludes that these reforms strike an appropriate balance between regulatory efficiency, operational flexibility, and interference protection.

The following notable changes were made to the draft item:

1. ¶ 90 – The FCC clarified that the two-step “Nationwide, Non-Site License” process was intended to apply across all frequency bands, but also asks if there should be bands excluded from this approach in para. 95.
2. ¶ 92 – The FCC clarified that under the Nationwide, Non-Site License approach, licensees may register sites before completing coordination but cannot begin operations until coordination and certification are complete.  This two-step process (license, then site registration/coordination) is intended to streamline licensing.  The FCC also added questions on whether coordination certifications, rather than submission of full reports, should be sufficient.
3. ¶ 203 – The FCC added an inquiry on how to handle pending applications during the transition, including whether to require supplements, establish a cut-off date for accepting part 25 applications, or allow pending applications to elect to convert to part 100.

On December 5, 2025, the FCC published the Notice of Proposed Rulemaking (“NPRM”) proposing to streamline space and earth station licensing under a new Part 100 of the FCC’s rules, replacing the existing Part 25, in the Federal Register, thereby setting comment dates.

Comments are due January 20, 2026.

Reply Comments are due February 18, 2026.

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