26-54 — Comment Digest

The need for adequate spectrum allocation to support aerospace and space operations.

Filers split on: “The Commission should explore additional spectrum resources to support aerospace and space operations.”

• Aerospace and Flight Test Radio Coordinating Csupport — The commenter highlights the critical need for sufficient spectrum access for aerospace operations, particularly emphasizing its importance for both general aerospace activities and new space initiatives to ensure their effectiveness.p. 1
• Space Exploration Holdingssupport — The commenter supports the FCC's proposal for streamlined spectrum access to benefit the commercial space sector, emphasizing the need for immediate access to established spectrum, a broader interpretation of allocations like Space Research Service (SRS), and the addition of a secondary allocation for Space Operations Service (SOS). They argue that this approach will alleviate congestion, unlock valuable non-Federal spectrum, demonstrate U.S. leadership in space policy, and facilitate innovative operations using existing commercial constellations.pp. 1, 2, 4, 5
• Information Technology and Innovation Foundatisupport — The commenter supports enabling flexible use of specific bands to enhance long-term spectrum productivity and accommodate future space operations, advocates for private leasing agreements between space operators and major license holders to further improve spectrum productivity, and emphasizes that ensuring sufficient spectrum availability is essential for fostering innovation and competitiveness in the U.S. space sector.pp. 4, 5
• Commercial Space Federation 05.11.26 CSF FCC Wsupport — The commenter argues that clear and predictable spectrum access pathways are essential for supporting new space activities that require high reliability and data throughput, while also stressing the importance of avoiding prescriptive rules that could hinder the evolution of the commercial space sector.pp. 2, 5
• Blue Originsupport — The commenter supports the FCC's recognition of a critical shortage of usable spectrum for telemetry, tracking, and command functions necessary for the growth of domestic space technologies, advocates for bandwidth needs to be determined by operational realities rather than arbitrary limits, and commends the FCC for its proactive approach to addressing this spectrum shortage.pp. 1, 3, 6
• Virgin Galacticsupport — The commenter highlights the unique nature of spaceflight operations and the necessity for efficient spectrum use in multiple directions, while also supporting the exploration of additional bands for suborbital operations to promote proactive spectrum management.pp. 2, 3

How new spectrum allocations for space operations may affect existing operations, particularly aeronautical and telemetry services.

Filers split on: “The Commission should require an assessment of how new space spectrum allocations impact existing operations.”

• Aerospace and Flight Test Radio Coordinating Csupport — The commenter emphasizes the importance of maintaining clarity about spectrum bands for new space operations to protect existing primary uses, particularly aeronautical mobile telemetry (AMT), and urges the Commission to consider the potential interference from new space operations, including out-of-band emissions. They support careful coordination with AFTRCC and Federal AMT coordinators, appreciate the Commission's recognition of the complexities involved, and stress the need for explicit input on mitigating risks to AMT operations, while also noting the lack of detailed comments due to the absence of proposed technical parameters.pp. 1, 2, 3, 5
• Information Technology and Innovation Foundatisupport — The commenter advocates for clearer guidelines to enhance the use of existing spectrum for new space operations while safeguarding current users, arguing that such regulations will prevent limitations on permissible operations and maximize the productivity of the spectrum utilized for telemetry, tracking, and control (TT&C).p. 3
• CORF National Academy of Sciences CORF DKT 26 modify — The commenter argues that the FCC must require ESO assignments in EESS bands to demonstrate they will not generate harmful interference, as per ITU regulations, and expresses concern that the FCC's case-by-case evaluation may not adequately protect sensitive EESS (passive) bands, which are critical for weather prediction and climate assessment; therefore, all EESS (passive) bands should be protected from new ESO assignments to ensure the integrity of these operations.pp. 1, 8, 9
• AnySignalmodify — The commenter believes that the NPRM's proposals, while constructive, do not adequately ensure necessary spectrum access for high-risk mission phases, and suggests that differentiating between routine and critical operations could lead to better spectrum policies tailored to each phase's unique needs; additionally, they emphasize that reliance on third-party services for critical mission requirements poses risks to safety and mission success.p. 2
• Stellar Frequenciesmodify — The commenter highlights that the primary challenge for new space missions is securing sufficient spectrum for downlinking mission data, a concern not sufficiently addressed in the current NPRM, and also argues that the existing coordination process is inefficient, proposing that an independent service could streamline the review of non-Federal spectrum requests.pp. 5, 9
• josep Jornet 26 54 INSI comments 5 11 26modify — The commenters suggest that the NPRM should consider additional frequency bands that could be used for telemetry, tracking, and control (TT&C) of emergent space operations, beyond those currently proposed.p. 2

The need for regulations to manage potential interference from intersatellite links.

Filers split on: “The Commission should mandate technical provisions to prevent interference from intersatellite links.”

• Astranis Space Technologiessupport — The commenter expresses caution regarding the licensing of ISL operations, advocating for technical provisions to ensure compatibility with existing satellite systems, while also arguing that aligning the U.S. regulatory framework for ISLs with international standards will enhance compatibility and operational efficiency in satellite communications.pp. 2, 4
• AST Scienceoppose — The commenter advocates for caution regarding ISLs due to potential interference risks, emphasizing the necessity of procedural safeguards and limitations on ISL proposals to protect existing satellite operations, particularly arguing against the inclusion of certain frequency bands like L-band and MSS spectrum in ISL authorizations.pp. 1, 2, 3
• Information Technology and Innovation Foundatioppose — The commenter believes that the existing framework for authorizing intersatellite links can be effectively utilized to enhance commercial spectrum usage, and argues that reducing regulatory requirements for intersatellite links will facilitate their use and improve the efficiency of spectrum utilization.p. 4
• Capella Spacesupport — The commenter supports the allowance of MSS ISLs for TT&C and data relay services, arguing that it modernizes satellite architecture, enhances communication efficiency, and provides regulatory certainty, while also noting that existing rules create uncertainty about space-to-space communications and that imposing additional requirements could burden smaller operators.pp. 1, 2, 3, 4, 5
• Blue Originsupport — The commenter advocates for establishing clear rules to streamline the licensing process and enhance mission planning certainty, supports allowing intersatellite links without additional authorization to promote emergent space operations while minimizing interference risks, and suggests that a database would reduce regulatory friction and simplify the application process for operators.pp. 4, 5
• Foundation for Defense of Democracies Spectrumsupport — A streamlined authorization process for intersatellite links would facilitate access for emergent space operators while minimizing interference risks.p. 8

The proposal to allow frequency piggybacking to enhance spectrum use efficiency.

Filers split on: “The Commission should adopt rules permitting frequency piggybacking for space operations.”

• Commercial Space Federation 05.11.26 CSF FCC Wsupport — The commenter advocates for clear rules regarding frequency piggybacking to enhance operational flexibility and efficiency in spectrum use.p. 4
• Information Technology and Innovation Foundatisupport — The commenter supports the idea of allowing spectrum piggybacking as a means to enhance the use of existing commercial allocations and increase overall spectrum productivity.p. 3
• AnySignalmodify — The commenter argues that relying on secondary access to a constrained band is inadequate for protected spectrum during critical operations, supports the current proposals as useful but insists they should lead to a more durable solution, and acknowledges the idea of piggybacking while cautioning that it cannot be the primary framework for spectrum access due to its limitations.pp. 2, 9, 12
• Virgin Galacticmodify — The commenter is encouraged by the proposal to allow leasing, believing it can lead to mutually beneficial arrangements for spectrum use; however, they also express concern that this practice could hinder efficient use of the spectrum and prefer coordinated use among multiple licensees.p. 2
• Blue Originsupport — The commenter highlights the operational importance of utilizing frequencies already authorized for client spacecraft and advocates for a broad definition of frequency piggybacking to encompass various emergent space operations, while also expressing encouragement for the FCC's proposal to provide additional spectrum, which they believe would greatly enhance access for non-Federal operators.pp. 2, 4
• Starfish Spaceoppose — The commenter argues that relying on client spectrum through piggybacking limits flexibility and could harm the economic viability of ISAM operations.p. 4

Whether the definition of TT&C should be expanded to include additional data types like video downlink.

Filers split on: “The Commission should expand the definition of TT&C to include video and data downlink for space operations.”

• Virgin Galacticsupport — The commenter believes that the definition of TT&C should not be limited and should allow for additional types of data transmission, which would benefit suborbital operations.p. 1
• Space Exploration Holdingssupport — The commenter believes that expanding the definition of TT&C to include video downlink will foster innovation and reduce uncertainty in emergent space operations, and supports the proposal as it would streamline operations for emergent spacecraft, reducing barriers and costs associated with traditional TT&C solutions.pp. 3, 4
• Information Technology and Innovation Foundatisupport — The commenter believes that a broader definition of TT&C will prevent the exclusion of future emergent operations and maximize the use of the TT&C bands.p. 3
• Astroscale U.S. Astroscale U.S.modify — The commenter believes that data necessary for safe spacecraft control should be included in TT&C, but warns against broad interpretations that could disrupt existing allocations.p. 3
• The ESO Collective Impulse ispace U.S. Vast ESsupport — The commenter argues that a broader interpretation of TT&C is necessary to encompass all communications essential for mission safety and control.p. 5
• Blue Originsupport — The commenter argues that including video and data downlink in the definition of TT&C is critical for effective spacecraft operations and monitoring.p. 3

The potential benefits of using sub-THz frequencies for satellite communications.

Filers split on: “The Commission should permit the use of sub-THz frequencies for satellite communications to improve efficiency.”

• Josep Jornet 26 54 fcc comment Finalmodify — The commenters advocate for the FCC to explicitly permit the use of the companion Part 5 filing mechanism for experimental satellite operations in sub-THz and THz bands, highlighting that these frequencies enable small satellites to achieve high antenna gain without large antennas, thus addressing constraints identified by the FCC. They also argue that current TRP-based limits do not consider the unique characteristics of modern antennas in sub-THz systems, potentially leading to unnecessary restrictions, and recommend evaluating interference potential using power flux density instead of traditional TRP-based limits.pp. 6, 7, 11
• josep Jornet 26 54 INSI comments 5 11 26support — The commenters advocate for the inclusion of frequency bands above 100 GHz in the FCC's considerations to support higher bandwidth requirements for innovative satellite services, and they argue that using sub-THz frequencies enables small satellites to achieve high link gains without large antennas, addressing a significant design constraint.pp. 4, 9
• mmWave Coalition 26 54 mmWC Draft final as filsupport — The Coalition highlights that the specific characteristics of the sub-THz bands make them ideal for satellite communications, as they can operate effectively without significant interference from atmospheric conditions.p. 3
• Astrolab FCC Docket 26 54 Astrolab WSS Respons — Astrolab advocates for the use of S-band frequencies for lunar operations until a robust relay network is established, as current lunar systems will rely on direct communications.p. 5
• ATT ATT Weird Space Stuff — The SDARS band has similar propagation characteristics to the Federal S band and is primarily licensed to SiriusXM, making it a viable option for TT&C operations.p. 2

Whether existing service definitions can accommodate new space operations without new classifications or allocations.

Filers split on: “The Commission should permit the use of existing service definitions for new space operations without creating new classifications.”

• Commercial Space Federation 05.11.26 CSF FCC Wsupport — The commenter believes that existing service definitions are flexible enough to accommodate new space operations without the need for a new service classification, which would promote innovation and avoid delays.p. 1
• The ESO Collective Impulse ispace U.S. Vast ESsupport — The commenter advocates for defining services based on their functional use to better support ESO operations and supports a flexible interpretation of ISS to accommodate modern space systems and their operational needs.p. 5
• Virgin Galacticsupport — Virgin Galactic argues that existing service definitions are flexible enough to accommodate new operations without the need for a separate allocation.p. 1