Part 25 Space Station Licensing Process and Timeline

The information provided in this webpage is for the convenience of applicants and is not controlling in case of discrepancies between this webpage and other Commission rules, orders, and releases. If you believe this webpage contains inaccuracies or omissions, please e-mail any concerns to satinfo@fcc.gov.

Introduction

The part 25 licensing process, administered by the Space Bureau, is primarily used for commercial, non-federal, services.  All applications are evaluated to make sure they are legally, technically, and otherwise qualified to be granted an FCC license, including a finding that the public interest would be served by a grant. Space station applications are processed either on a “first-come/first served” basis (GSO-like) or in “processing rounds” (NGSO-like). All space station licenses are subject to a license term, performance bonds and implementation milestones. Earth stations (e.g., gateway stations and user terminals) are licensed separately from the space stations with which they communicate.

Applicants seeking U.S. market access for non-U.S. licensed space stations will be subject to the same procedures as applicants for U.S. licenses.

GSO-like (“First-come/First-served") vs NGSO-like (Processing Rounds) Overview

For “GSO-like” applications: License applications for GSO-like satellite operation are placed in a queue and considered in the order that they are filed (47 CFR § 25.158(b)). The application will be reviewed to determine whether it is acceptable for filing within the meaning of section § 25.112 (i.e., not dismissed). If not acceptable for filing, the application will be returned to the applicant. (47 CFR § 25.158(b)(1)). If it is acceptable for filing, the Commission will issue a public notice (PN) announcing that the application has been found acceptable for filing and will give interested parties an opportunity to comment or file a petition to deny. (47 CFR § 25.158(b)(2)). Although the time of filing establishes an applicant’s place in the queue, the applicant loses this status if the application is found not acceptable for filing and dismissed.

For “NGSO-like” applications:  Applications for NGSO system licenses are considered in groups based on filing date, under a processing round procedure.  Pursuant to the Commission’s rules, a license application for “NGSO-like” satellite operation that satisfies the acceptability for filing requirements is reviewed to determine whether it is a “competing application” or a “lead application.”  A competing application is one filed in response to a public notice (PN) initiating a processing round.  Any other application is a lead application.  Competing applications are placed on PN to provide interested parties an opportunity to file pleadings in response to the application.  Lead applications are also placed on PN.  The PN for a lead application initiates a processing round, establishes a cut-off date for competing “NGSO-like” satellite system applications, and provides interested parties an opportunity to file pleadings in response to the application.

Part 25 Space Station Authorization Timeline

The overall part 25 space station licensing process can vary in length, depending on the type of application, frequency bands requested, and complexity of the system.  While a straightforward, uncontested application for a GSO satellite or small satellite may have processing times on the order of 6-9 months; some applications may take longer to process, particularly where there are waiver requests, requests for use of frequency bands shared with federal operators, requests for a novel type of operation, when the application is subject to processing round procedures, or has other significant issues.

A breakdown of the typical satellite licensing steps is shown below. This process includes review, 30-day Public Notice process, submission of ITU filings, and coordination.

Pre-Submission

Prior to submitting a part 25 space station application the Space Bureau recommends applicants review the following resources:

• Part 25 Space Station Licensing Processes, Terms and Costs
• Part 25 Space Station License and Market Access Checklist
  • This checklist includes templates and example documents for a part 25 application. It also describes software that will need to be used for ITU filing preparation and post mission disposal analysis.
    • For applicants with no previous experience, specialized software tools such as NASA’s Debris Assessment Software (DAS) and ITU filing tools may require additional time with which to become familiar.
  • For communications with an earth station in the U.S. or within U.S. jurisdiction, the FCC reviews the foreign licensed space station through “market access” procedures. While this is nearly identical to the process for U.S. licensed space stations there are nuances in the Narrative. Templates are provided in the linked Checklist above for both market access (petition for declaratory ruling) applications and space station licenses (launch and operating authority).
  • It is important to note that applicants should arrange for a competent registration authority to submit materials to the U.N. Office of Outer Space Affairs and ensure completion of the registration process following launch of the satellites.
• FAQ: Space Stations

Helpful Tip:  We also recommend engaging with and informing the Space Bureau via satinfo@fcc.gov of your plans to file.

1.1  Confidentiality Filings Guidance

We expect that only in rare instances will information need to be filed as part of an application with a request for confidentially.  Confidential treatment means that the information will not be routinely made public, but it does not foreclose the possibility of third parties obtaining the information through a request under the Freedom of Information Act (FOIA). Most space station and earth station applicants can file all the necessary information in support of their applications with the FCC without needing to request confidential treatment.  The Commission does not grant confidential treatment for entire applications.

In the rare instance that an applicant believes that it has a basis to request confidential treatment of particular information submitted as part of an application, questions about confidentiality should be raised as soon as possible, as issues with processing confidentiality requests can slow down the authorization process.

Relevant provisions regarding requests for confidential treatment are set out in sections 0.457 and 0.459.of the Commission’s rules.  Casual requests (including simply stamping pages “confidential”) will not be considered. Any requests for confidential treatment must be narrowly tailored.  Such information is also submitted electronically in ICFS, and the applicant should take care in the filing process to designate documents appropriately.  See also https://docs.fcc.gov/public/attachments/DA-20-579A1.pdf

Helpful Tip – Erroneous Headers and Footers:  If you are submitting documents to the FCC, make sure to review all document footers and headers to make sure that none are marked “confidential” (unless the intention is that it be submitted alongside a request for confidential treatment), or have other erroneous markers.

“Pre-Coordination” with other Frequency Band Users

The Commission encourages applicants to review both federal and non-federal service allocations in the proposed bands of use (and adjacent bands) and contact incumbent operators in the band to engage in “pre-coordination” before an application is filed, or as soon as possible.

Depending on the frequency band involved, this may include, for example, contacting the spectrum coordination offices at different federal agencies.  If you have questions about the relevant contact information, please contact satinfo@fcc.gov.

Helpful Tip:  In 2021, the National Telecommunications and Information Administration (NTIA) released a report titled: “The Spectrum Needs of U.S. Space-Based Operations: An Inventory of Current and Projected Uses, which includes an Appendix surveying major unclassified systems and uses for U.S.-based space operations at frequencies from 137 MHz to 1000 GHz:

Application Submission

Once an applicant has completed the pre-submission phase of the process, and in so doing, has confirmed that all elements of the part 25 Checklist are prepared in accordance with the Commission’s rules, it is ready to submit its application.  Under the part 25 rules, an application that does not meet the Commission’s rules will be deemed unacceptable for filing and dismissed unless a waiver of the acceptability criteria is granted.  All applications must be submitted electronically to ICFS (formerly IBFS). No paper applications will be accepted.

Helpful Tip:  Make sure you have all the elements ready to file at the outset; although applications can be supplemented to respond to Commission staff questions, the original filing should have all the required documents or may be dismissed.

3.1  ICFS Tutorials

Tutorials with directions for using the updated ICFS system will be made available after the updated ICFS system is released. 

Helpful Tip:  There is currently an email address and help line for ICFS-specific questions: IBFSINFO@fcc.gov and 202-418-2222. Please use these for ICFS-specific questions, rather than for general questions about your application.

Review for Acceptability for Filing

Once received, Commission staff conduct an initial review of each application for completeness, acceptability for filing and compliance with procedural and substantive rules before applications are placed on Public Notice for comment.

Space Bureau staff will either:

• Determine that an application for authority to operate a space or earth station is acceptable for filing and place it on public notice; or
• Notify the applicant that staff has identified questions, errors, or omissions, and that the application will not be placed on public notice until after these questions, errors, or omissions are addressed by the applicant to the satisfaction of the Bureau. 

The Commission may request from any party at any time additional information concerning any application, or any other submission or pleading regarding an application, filed under part 25. 47 CFR § 25.111(a).

An application can be dismissed and returned to application without accepting the application for filing for several specified reasons (47 CFR § 25.112):

• Applicant is defective with respect to completeness of answers to questions, informational showings, internal inconsistencies, execution, or other matters of a formal character. (47 CFR § 25.112(a)(1)).
• Application does not substantially comply with the Commission’s rules, regulations, specific requests for information, or other requirements. (47 CFR § 25.112(a)(2)).
• The application is identical to a pending application that was timely filed. (47 CFR § 25.112(a)(4)).

The first two of these can be waived, either upon request of applicant or on FCC’s own motion, to allow the applicant to avoid dismissal and the application to be reviewed on the merits. 47 CFR § 25.112(b).

Typical issues that may prolong staff review and delay acceptance for filing include internal inconsistencies in the application, omission of information required by the rules, omission of waiver requests, and/or missed filing deadlines.  In general, a delay in acceptance for filing will also result in a delay in action on the application.

Depending on the frequency bands requested, some applications may require an additional rulemaking processes or resolution of issues at the ITU World Radiocommunication Conference (WRC).

Helpful tip: Consider using keywords and phrases from our rules in the Narrative and Technical Annex. Applications are initially screened by Commission staff to parse what information has been provided and what information still needs to be obtained.  Keywords and phrases from Commission rules help staff complete the initial screening and move on to more in-depth analysis more quickly. If not using keywords and phrases, consider citing any disclosures with the relevant rule.  While not required, some applicants provide a compliance matrix, mapping the relevant regulations to the specific section of the application in which compliance of the regulation is furnished.

Full Review

In this phase of the process, applications undergo technical, legal, and managerial review. It is important to note that the “Full Review” runs concurrently with the comment period, generally extending after the commenting period is over. The coordination process also runs concurrently with the Full Review.

During Full Review, engineers review the Exhibits and for “Part 25” Licenses the Schedule S for completeness of engineering information required to be provided under section § 25.114. Attorneys review the required Forms (Form 312 for “Part 25”, STA Forms) and the Narrative. The Commission may reach out to applicants to seek additional technical information during this period.

Coordination

Once a part 25 space station application is submitted, an operator is responsible for initiating and completing good-faith coordination with federal and non-federal incumbents, as well as international coordination. In the future, a Coordination FAQ will be provided to offer a further deep dive on this part of the Transparency Initiative.

Public Notice and Comment Period

If an application is not dismissed as defective, then a public notice (PN) will be issued announcing that the application has been accepted for filing. The Commission will place all earth stations and GSO space station applications on PN within 30 calendar days after the application is filed in ICFS, and all NGSO space station applications within a 60-day timeline.

The issuance of the PN triggers the start of a 30-day comment period on the proposed operations, and no space station application that has appeared on public notice will be granted until the expiration of a period of 30-days (47 CFR § 25.151(d)). The Commission is not required to place certain applications on PN prior to action including, among others, applications for special temporary authority. (47 CFR § 25.120).  The Commission retains discretion to place an application on public notice if it believes the information is of public significance. (47 CFR § 25.151(a)(7))  

Once the 30-day comment period is complete, the Commission will evaluate any objections or other comments, responses, and replies, and make a determination on the merits regarding the application—including, for applications that are granted, what conditions, if any, should be placed on a particular license or grant of market access.

If comments are filed during this period, an additional 15-day reply comment period is established.

Interested parties and the applicant may make filings in advance of an application being placed on PN.

• Applications for space station licenses are default classified as “restricted” proceedings under the FCC’s rules governing ex parte presentations, 47 CFR § 1.1208, meaning that oral or written communications to the Commission are not permitted by any party other than the applicant regarding the merits of the application, unless written communications are also served on the applicant (filing the written presentation electronically in ICFS is not sufficient). Commission staff has the authority to change the the ex parte status of an application to “permit-but-disclose” under the FCC rules, 47 CFR § 1.1200, either on staff’s own motion or at the request of the applicant or a third-party.

A weekly Public Notice of space station applications accepted for filing is issued usually on Fridays, as provided in the rules. 47 CFR § 25.151(a).

The opening paragraph of the weekly “accepted for filing” public notice states, “The Commission reserves the right to return any of the applications if, upon further examination, it is determined that the application is not in conformance with the Commission's rules or its policies.”

Appearing on the “accepted for filing” public notice has significant legal importance, in that it determines an applicant’s place in the queue (for GSO-like applications) or commencement of, or inclusion in, a processing round (for NGSO-like applications).

Application Amendments (prior to Application grant)

An amendment to a filing occurs when an applicant wishes to change an aspect of their part 25 submission prior to FCC authorization. “Part 25” applications may be amended until:

• A public notice is issued stating that a substantive disposition of the application is to be considered at a forthcoming Commission meeting, or
• A final order disposing of the matter is adopted by the Commission. 47 CFR § 25.116(a).

Amendments must be filed electronically, in same manner as applications. 47 CFR § 25.116(e).

“Major” amendments are subject to the public notice requirements, 47 CFR § 25.116(b), and may cause application to be considered as a newly filed application (resulting in loss of place in processing round) or cause an application to lose its status relative to later-filed applications in the “queue”. 47 CFR § h325.116(c) and (d). Generally, a major amendment is one that:

• Increases the potential for interference
• Involves changes to a Schedule S or other documents

Applicants are responsible for the continuing accuracy and completeness of information furnished in a pending application or in Commission proceedings involving a pending application. 47 CFR § 1.65. Whenever the information furnished in the pending application is no longer substantially accurate and complete in all significant respects, the applicant must promptly as possible and in any event within 30 days, unless good cause is shown, amend or request the amendment of the application so as to furnish such additional or corrected information as may be appropriate. 47 CFR § 1.65(a). Such corrected information may include things such as a change in legal counsel representing the applicant, or a change in address or ownership of the company prior to grant of the application. (After grant of an application and the issuance of a license or grant of market access, changes in ownership will need to be approved by the Commission through the filing of an application for transfer of control or assignment under section 25.119 of the Commission’s rules.)

Application First Grant

Space station applications are granted if the applicant is legally and technically qualified and the proposed space station will not cause harmful interference to any previously authorized operations.

ICFS shows actions taken in the system, but does not automatically notify applicants that a grant has been issued. However, grants appear in the weekly “Actions Taken” Public Notice that the Commission usually releases on Fridays. Additionally, the Bureau generally sends a courtesy copy of grant stamps via email to the applicant.

9.1  Conditions List

Grant of an application is subject to the legal and technical specifications set forth in the application, and operations under the grant must comply with all FCC rules, unless a particular rule is specifically waived as part of the grant.

On occasion, “straight” or “clean” application grants are issued, meaning that there are no license conditions. More commonly, a license grant will list specific conditions with which each applicant must comply. Common types of conditions are those that pertain to:

• Specific frequency band usage, sharing procedures and whether use is on a primary or secondary basis
• Coordination agreements or showings that the applicant will not cause harmful interference prior to commencing operations in a specific band
• Timely provision of information required for Advanced Publication, Coordination, and Notification of the frequency assignments for a system or space station including due diligence information pursuant to Articles 9 and 11 of the ITU Radio Regulations
• Specific band related operations and conformance with the US Table of Frequency Allocations
• Operations in a specific band may be subject to a condition stating that such operations will be conducted on a non-interference, non-protected basis
• Specific footnotes of the ITU allocations

Post-Grant Items

Applicants are required to update application materials as needed including the point of contact, which must be updated within 10 days of any changes. Applicants will be required to submit a modification for substantive changes to the mission or mission plan that materially differ from what was granted.

Grantees must:

• Secure any necessary performance bonds and submit documentation. Bonds must be posted within 30 days after application grant.
• Prior to commencing operations, if not previously provided, submit updated locations for TT&C operations.
• Submit notice of commencement of operations, which would notify the Space Bureau of the launch and must include a certification that the applicant has completed any requirements on which operations are condition.If there are milestone conditions in the grant document that have been met, the operator should submit notice of milestone completion, and a request to release the bond, if appropriate.
• On June 30 of each year, a space station licensee or market access recipient must provide a current listing of the names, titles, addresses, email addresses, and telephone numbers of the points of contact for resolution of interference problems and for emergency response. Contact personnel should include those responsible for resolution of short-term, immediate interference problems at the system control center, and those responsible for long-term engineering and technical design issues. (47 CFR § 25.171)

Modifications of License (after Application grant)

Once a license has been granted, it may be modified by the Commission, either at the request of the licensee (usual process) or by the Commission on its own motion (rarely done), if the modification serves the public interest. 47 CFR § 25.117.

License holders must update their applications with changes to information provided in their application materials. The modification must be filed and approved by the FCC prior to those changes being made.

For example, if your deployment altitude ends up differing from your granted application, it is important to update your FCC file, as operations following deployment at an altitude other than that granted are unauthorized. Additionally, this information is communicated during FAA payload review consultations and is required to match across all parties.

After grant of an application and the issuance of a license or grant of market access, changes in ownership will need to be approved by the Commission through the filing of an application for transfer of control or assignment under section 25.119 of the Commission’s rules.

One circumstance is ex parte filings under the rules in the bullets below. In addition, although Section 25.154(a) requires most pleadings to be filed within 30 day AFTER PN, section 25.154(b) undoes that time restriction and allows the Commission to treat pleadings made in violation of 25.154(a) as informal objections, which we have in effect treated the same as legitimately filed pleadings under 25.154(b).