Space Stations

FCC Space Station Licensing Process

With limited exceptions, prior authorization from the FCC is required for satellite communications.¹  The Commission’s licensing of space stations is “facilities-based,” meaning that the license is associated with a specific satellite. Some administrations issue a spectrum license in addition to a satellite license, however, in the U.S. there is no license for use of spectrum that is separate from the FCC license to operate the space station using the spectrum.   

The FCC does not authorize, or “license”, space stations (i.e., satellites) controlled by U.S. government agencies (“federal” stations).  The FCC also does not license space stations already licensed by other countries.  However, the FCC will grant non-U.S. licensed space stations access to the U.S. market through a process in which U.S.-licensed earth stations are authorized to communicate with non-U.S. licensed space stations.²

The FCC licenses space stations through several distinct processes, each of which are covered in the subsequent sections.³

• Part 25 Space Station License and Market Access Checklist
  • Narrative for non-U.S. Applications (Petition for Declaratory Ruling) Template
  • Narrative for U.S. Applications (Launch Operating Authority) Template
  • Form 312, Question 40: Corporate Ownership Template
  • Form 312, Question 40: Corporate Ownership Example
  • FCC Cover Letter for ITU SpaceCap Filing Template
  • ITU Cost Recovery Letter Template
• Part 25 Space Station Licensing Process and Timeline
• Part 25 Space Station Licensing FAQ
• Small Satellite and Small Spacecraft Licensing Process
• Space Station Open House Event Nov. 1, 2023 - Recording
• Space Station Open House - Public Notice

“Part 25” Commercial (Non-Federal) Space Station Licensing 

The FCC’s rules and regulations are codified in Title 47 of the Code of Federal Regulations (CFR). Title 47 of the CFR is available for free. The rules and regulations for satellite communications are contained in part 25 of Title 47. Accordingly, “part 25” refers to the set of rules that govern the regulation of most non-federal satellite activities, and that the Space Bureau uses to evaluate applications for space and earth station authorizations. 

• All applications for authority to operate space stations under part 25 generally require: 
  • Information about the frequencies requested for use, including relevant technical details.
  • Submission of a plan for orbital debris mitigation. 
  • For U.S.-licenses, preparation of materials for an International Telecommunication Union (ITU) satellite network filing, which is submitted by the FCC to the ITU.  
• The FCC also issues grants of “Special Temporary Authority (STA)”.  These are limited grants for extraordinary circumstances requiring temporary operations in the public interest⁴.  Under part 25, STAs do not typically substitute for space station licenses. 
• “Market Access” pertains to the authorization of U.S. licensed earth stations to communicate with non-U.S. licensed satellites. The review process for market access applications is nearly identical to the process used for U.S. licensed satellite applications.  
• The FCC’s Part 25 also includes the “Small Satellite” and “Small Spacecraft” Licensing Processes, which are designed for satellites and other spacecraft meeting certain criteria, including having short orbital lifetimes.  These processes have lower application and regulatory costs than regular part 25 satellite licenses, and are also often associated with shorter processing times than regular part 25 licenses.  
• Part 25 rules also cover licensing of earth stations in the U.S. 
  • This includes, for example, modifications necessary to the licenses of existing earth stations to add additional satellite points of communication. 
• The FCC coordinates requests to operate on shared federal frequency bands with the National Telecommunications and Information Administration (NTIA), an Executive Branch agency whose responsibilities include managing the federal use of spectrum. 

“Part 5” Experimental Licensing  

The rules and regulations for experimental radio service are contained in part 5 of Title 47.  This licensing process is:

• For experimental missions, which are generally for the purposes of experimentation, product development, and market trials, respective to Part 5 rules on purpose and scope.    
• Administered by the FCC’s Office of Engineering and Technology (OET).   

Part 5 experimental space station applications:   

• Are filed through the FCC’s Experimental Licensing System (ELS). 
  • Experiments operating 6 months or less file a Special Temporary Authority (STA) under Part 5.
  • Experiments longer than 6 months file using the Form 442 application. 
• Require the submission of an ITU satellite network filing and orbital debris mitigation (ODM) plan prior to grant, as well as the commitment to pay ITU cost recovery fees.  OET coordinates with the Space Bureau on the review of these applications. 
• Are authorized on an unprotected, non-interference basis (NIB). 
• Can be in any frequency band, but applicants should consider allocated space bands. 
• The FCC coordinates requests to operate on shared federal frequency bands with the National Telecommunications and Information Administration (NTIA), an Executive Branch agency whose responsibilities include managing the federal use of spectrum. 

“Part 97” Amateur Radio License  

The rules and regulations for amateur radio service are contained in part 97 of Title 47.  Satellites can be amateur space stations.  The license grantee of each amateur space station must make written notifications to the Space Bureau before launch, after launch, and after termination of transmissions.  FCC regulations permit amateur satellite operations if the space station:

• Operates in appropriately allocated amateur frequency bands,  
• Is controlled by a person holding an amateur station license, and 
• Is more than 50 km above the Earth’s surface aboard “any craft that is documented or registered in the United States.”

Communications must be conducted by amateurs for amateur radio purposes (i.e., self-training, intercommunication and technical investigation carried out by a duly authorized person interested in radio technique solely with a personal aim and without pecuniary interest).  
The following materials are needed to support an FCC finding that an amateur satellite is “documented”:

• Letter from the International Amateur Radio Union (IARU) documenting successful coordination 
• Detailed technical description of the design and operation of the spacecraft
• Copy of the ITU filing  
• Orbital Debris Mitigation (ODM) Plan  
• Point of Contact information of Licensed Control Operator 

License Term  

License terms vary based on license type:  

Geostationary-Orbit (GSO) space stations:  For GSO space stations licensed under part 25, the license term will begin at 3 a.m. Eastern Time on the date when the licensee notifies the Commission section 25.173(b) that the space station has been successfully placed into orbit at its assigned orbital location and that its operations conform to the terms and conditions of the space station authorization. 

Non-Geostationary Orbit (NGSO) space stations: For NGSO space stations licensed under part 25, sections 25.122 and 25.123, the license period will begin at 3 a.m. Eastern Time on the date when the licensee notifies the Commission (section 25.173(b)) that operation of an initial space station compliant with the license terms and conditions and that the space station has been placed in its authorized orbit.  Operating authority for all space stations subsequently brought into service pursuant to the license will terminate upon its expiration. 

NGSO Small Sats/Small Spacecraft:  For NGSO space stations granted under the part 25 streamlined processing rules for small satellites or small spacecraft, sections 25.122 and 25.123, the license period will begin at 3 a.m. Eastern Time on the date when the licensee notifies the Commission (section 25.173(b)) that operation of an initial space station is compliant with the license terms and conditions and that the space station has been placed in its authorized orbit and has begun operating.  Operating authority for all space stations subsequently brought into service pursuant to the license will terminate upon its expiration. 

The document granting STA will state the commencement and end dates of the authorization.

License Cost Structure 

Applicants must pay appropriate fees at the time of filing and on an annual basis thereafter for part 25 licensees and market access grantees, once their satellite is licensed and operational.  For a further description of the FCC’s Regulatory and Licensing fees see https://www.fcc.gov/licensing-databases/fees.  It is important to note that fees are subject to change, and those included below are accurate as of the publication date of this document.  Applicants may begin construction of a space station at their own risk, as there is no construction permit required 47 CFR § 25.113(f). 

In addition, in most cases there are costs to part 25 licensees related to maintaining a surety bond following grant of a license.  This bond is required by the FCC’s part 25 rules in order to ensure that the licensee is meeting certain deployment milestones associated with their satellite or satellite system license.⁶

^[1]47 CFR section 25.102(a) “No person shall use or operate apparatus for the transmission of energy or communications or signals by space or earth stations except under, and in accordance with, an appropriate authorization granted by the Federal Communications Commission.”

^[2]See paragraph 3 of FCC 97-398, IB docket No. 97-142, 95-22. This is consistent with commitments made by the United States as part of the 1997 World Trade Organization Basic Telecommunications Agreement.

^[3]Unless indicated otherwise, when we refer to the term license or licensee in this document, we also include market access grants or grantees.  Further, we use the terms space station and satellite interchangeably.

^[4]47 CFR § 25.120.

^[5]The Commission reserves the right to grant or renew licenses for less than 15 years if, in its judgment, the public interest, convenience and necessity will be served by such action.  47 CFR § 25.121(b).

^[6]47 CFR §§ 25.164, 25.165. When the Commission adopted the bond requirements in 2003, the Commission reasoned that requiring satellite licensees to make a financial commitment to construct and launch their satellites would help deter speculative applications and thus prevent valuable spectrum resources from lying follow.  When the Commission adopted a revised escalating methodology for bond and milestone rules in 2015, which increases operators’ liability over time, the Commission aimed to further incentivize satellite operators to construct and launch spacecraft expeditiously or surrender their authorization early.

^[7]Refer to Updated Procedures for Surety Bonds and Clarifying procedures for Surety Bonds.