Yesterday, TechFreedom published a new paper exploring the developing conflict between the Federal Communications Commission’s (FCC) desire to create an “assembly line” for processing satellite applications and the reality of deploying megaconstellations.
“Creating an efficient assembly line for satellite applications will be challenging,” said James E. Dunstan, TechFreedom’s Senior Counsel. “Like Henry Ford’s assembly line, satellite deployment would require every step—design, manufacturing, licensing, launch—to be meticulously coordinated. But even on a perfect assembly line, the process fails if products start to pile up because of an inability to deliver. Without firm rules requiring deployment, the FCC’s assembly line process will be choked by paper applications for hundreds of thousands—or even millions—of satellites that can’t possibly be deployed.”
“Megaconstellations present a situation that could crush the assembly line,” warned Dunstan. “As constellation sizes grow, potentially up to a million satellites, the ability to deploy half of the constellation within the six-year milestone window of the Commission’s rules will be impossible. In all likelihood, megaconstellation license holders will have to go back to the FCC to seek a waiver of the interim deployment rule, requiring 50% of the satellites to be launched within six years after license grant.”
“There are several solutions the Commission should consider,” Dunstan concluded. “The least desirable path would be to maintain the status quo—either freezing constellation sizes to those satellites launched at the end of six years or continuing to grant extensions. The Commission could also consider just scrapping the deployment milestones, but that would completely defeat the purpose of deterring unrealistic applications. Finally, the Commission should study a ‘cap and defer’ option, whereby licenses are modified to cap the number of satellites at those deployed during the first six years, and deferring all undeployed satellites to a later processing round. But something must be done before the processing line breaks down.”
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Find this paper, “When the Assembly Line Breaks Down: Reassessing FCC Licensing of Next-Generation Satellite Systems” on our website, and share it on Twitter and Bluesky. We can be reached for comment at media@techfreedom.org. Read our related work, including:
- Comments to the Office of Commercial Space (OSC) on its framework to establish a “Mission Authorization” regulatory regime for innovative space activities (Mar. 13, 2026)
- Comments on the NPRM to modernize the FCC’s space and earth station licensing process (Jan. 20, 2026)
- Comments to the European Commission regarding the EU’s Draft Space Act (Nov. 7, 2025)
- Comments to the Dept of Commerce on the Draft EU Space Act (Aug. 15, 2025)
- We need a National Space Council to chart our future in outer space, SpaceNews (Jan. 23, 2025)
- Comments on the mitigation of orbital debris in the new space age, (June 27, 2024)
- Comments on NASA’s Lunar Non-Interference Questionnaire, (June 7, 2024)
- Comments to the FCC on In-Space Servicing, Assembly, and Manufacturing (ISAM) (Apr. 29, 2024)
- Do We Still Have the Right Stuff?, City Journal (Dec. 2023)
- SpaceX Makes Progress on Second Test of Starship, Reason (Nov. 18, 2023)
- Tech Policy Podcast #349: The State of Space Exploration (July 25, 2023)
- Regulating the space economy is vital for America’s continued global leadership, Washington Examiner (July 15, 2023)
- Written testimony before the House Committee on Science, Space, and Technology on U.S. leadership in commercial space (July 13, 2023)
About TechFreedom: TechFreedom is a nonprofit, nonpartisan technology policy think tank. We work to chart a path forward for policymakers towards a bright future where technology enhances freedom, and freedom enhances technology.