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FCC Petition for Rulemaking: Shotclocks

On November 10, 2022 Whitney Lohmeyer (OSSTP Director), Kaitlyn Fleming (OSSTP Undergraduate Researcher), and Argyris Kriezis (OSSTP Alum Researcher) submitted a Proposed Rulemaking (PRM) to the Federal Communications Commission (FCC) regarding the licensing of Non-Geosynchronous (NGSO) satellite constellations. The primary two goals of this petition were to acknowledge the level to which the International Bureau (“IB”) is overloaded and understaffed and identify systematic issues with the NGSO filing process that has created a bottleneck in the U.S licensing process. Based on input from numerous industry stakeholders, the team determined that the introduction of a “shot clock,” would offer the exploration of holistically streamlining the authorization process, and help combat the increasing wait times that applicants face.

An April 2022 OSSTP Group report, authored by Kriezis and Lohmeyer, showed that since 2016, more than twenty distinct FSS entities have filed for a total of more than 70,000 satellites to serve the U.S. Market. Additional detail on the specific frequency ranges and operator information of each round is contained within the April 2022 OSSTP Group’s Industry Report, but in summary, these applications took place across four processing rounds with the following submission dates and frequencies:


  • November 15, 2016: Ku-/Ka-band

  • March 1, 2017: V-band

  • May 26, 2020: Ku-/Ka-band

  • November 4, 2021: V-band


Between the first two processing rounds, the average processing time increased from 2 years, to 2.9 years. Furthermore, of the applicants that have received authorization, three systems, Kepler, SpaceX and OneWeb, have begun launching their systems. Figure 1, created by Abigail Omer (Undergraduate Researcher), depicts the individual launch events as well as the cumulative number of OneWeb and Starlink satellites in orbit. Kepler was not included in this figure, but has launched nineteen satellites


Figure 1: Individual launch events and cumulative number of OneWeb and Starlink satellites

The trend of increasing wait times has continued into the third and fourth processing rounds. In the May 2020 round, only two of the ten applications have received a First Action, while the remaining applications have been under review for more than 2.5 years. In the most recent November 2021 V-band round, all twelve of the submitted applications have been under review for more than a year. The Commission has a major backlog of applications, processing times for modifications are increasing, and a fifth Processing Round is imminent.


While there is no consensus on the length or general efficacy of a “shot-clock” the OSSTP Group is aligned with the discussion draft legislation, and petitions the FCC to implement a default one-year “shot-clock.” We believe that the implementation of a one-year “shot-clock” on NGSO applications would offer applicants technical and financial clarity, as well as incentivize the rapid development and deployment of these systems, allowing them to expeditiously reach underserved and unserved communities. 

This work has already had impacts on the policy being drafted around this issue. Our Petition has influenced concurrent attempts to address this issue, including being referenced in SpaceX’s ex parte and consulting on an effort led by the House of Representatives’ Energy and Commerce Telecommunications subcommittee: House Energy and Commerce Committee Republican Leader Cathy McMorris Rodgers (R-WA) and Committee Chairman Frank Pallone Jr.’s (D-NJ) Satellite and Telecommunications Streamlining Act. On February 2, the House began their hearing “Launching Into the State of the Satellite Marketplace” discussing many of the same issues identified in our Petition.

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