Yesterday, TechFreedom filed reply comments in response to the Federal Communications Commission’s (FCC) Further Notice of Proposed Rulemaking (FNPRM) seeking comment on changes to the Commission’s rules aimed at streamlining the process for granting satellite and earth station applications.
“The FCC must fundamentally change its approach to licensing,” said James E. Dunstan, TechFreedom’s General Counsel. “Demand for licenses in the space services won’t be met with some minor tweaks to the process. As the Report and Order and FNPRM make clear, just coaching up applicants to better understand the systems and forms of the FCC is only a small part of what needs to happen for the FCC to keep up with the wave of applications for space spectrum uses. Unfortunately, most of the measures adopted in the Report and Order will only impact at the margins; they lack a comprehensive approach to regulatory changes necessary to allow the FCC staff to keep pace with innovations from the commercial space sector.”
“The reliance on special temporary authority (STA) is counterproductive,” Dunstan continued. “When STAs become the norm rather than a safety valve for emergencies, that system will ultimately break down. Rather than exploring the root cause of why so many STAs are being filed, the FNPRM instead seeks to make the STA process more efficient, including allowing automatic extensions to STAs while the underlying applications remain in the processing queue. TechFreedom does not oppose such changes, but only so long as the Commission also continues to seek ways to both reduce the number of applications that it has to process and the timeframe in which it can process such applications.”
“Shot clocks would force all stakeholders to up their game,” Dunstan concluded. “Shot clocks speed processing times, often forcing agencies to revamp their review and licensing regimes. They also force interested parties to timely file any objections they have, not wait months to file in an effort to slow down their competitors.”
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Find these reply comments on our website, and share them on Twitter, Bluesky, Mastodon, Facebook, and LinkedIn. We can be reached for comment at media@techfreedom.org. Read our related work, including:
- Our comments to the FAA and DOT on mitigation methods for the creation of orbital debris (Dec. 22, 2023)
- Do We Still Have the Right Stuff?, City Journal (Dec. 2023)
- SpaceX Makes Progress on Second Test of Starship, Reason (Nov. 18, 2023)
- SpaceX, DOJ, INA and ITAR — Acronyms (and Common Sense) Run Amok, DC Journal (Sep. 25, 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)
- Our written testimony before the House Committee on Science, Space, and Technology on U.S. leadership in commercial space (July 13, 2023)
- Tech Policy Podcast #348: The State of Space Regulation (July 11, 2023)
- Regulating Outer Space: Of Gaps, Overlaps, and Stovepipes, Center for Growth and Opportunity (July 10, 2023)
- Our amicus brief urging the D.C. Circuit not to extend the National Environmental Policy Act (NEPA) into outer space (June 20, 2023)
- Our comments to the FCC on supplemental coverage from space (May 12, 2023)
- Our comments to the FCC on expediting initial processing of satellite and earth station applications (Mar. 3, 2023)
- Our comments to the FCC on In-Space Servicing, Assembly, and Manufacturing (Oct. 31, 2022)
- Our comments to NASA on the “Moon to Mars Objectives” (June 3, 2022)
- Our comments to the FCC on revising spectrum sharing rules (Apr. 25, 2022)
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.
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