Washington, D.C., February 18, 2026
Before the Federal Communications Commission,
Washington, D.C. 20554
In the Matter of
Space Modernization for the 21st Century
(SB Docket No. 25-306)
REPLY COMMENTS OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society (AAS)1, the major organization of professional astronomers in the United States representing over 8500 members, appreciates the opportunity to provide reply comments in response to this Public Notice (FCC 25-69) regarding proposed changes to the Federal Communications Commission (FCC) licensing process for space and Earth stations.
We reiterate our appreciation for the Commission’s continued recognition of the Radio Astronomy Service (RAS) as serving the public interest and the inclusion of commensurate coordination requirements under this new licensing framework. In these reply comments, we endorse recommendations from other organizations to enable continued preservation of U.S. scientific capabilities while supporting a growing space industry.
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First, we strongly support the recommendation from the National Science Foundation (NSF) National Radio Astronomy Observatory (NRAO)2 that the Part 100 rules require an assessment of the optical brightness and visual impact of the proposed operation, subject to public comment. There are already operators seeking a license from the FCC who are not selling radio spectrum, but rather optical light.3 Therefore, this consideration should be part of the FCC’s evaluation of whether the proposed system serves the public interest, especially when such satellites have the potential to compromise the effective operation of federally funded astronomical facilities.
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We strongly endorse the recommendation from NRAO that satellite operators should make publicly and freely available the most accurate and current ephemeris data in standard machine-readable formats. This level of transparency is critical for mitigating the impacts of optical satellite streaks and radio frequency interference on astronomical observations.
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We appreciate the Commission’s inclusion of protections for the RAS in the 1610.6-1613.8 MHz band, which is used to elucidate the properties of star-forming gas clouds and measure the masses of supermassive black holes in the centers of galaxies. However, we share the concerns expressed by the National Academies’ Committee on Radio Frequencies (CORF)4 that Proposed Section 100.283(c)(2)(i) fails to reference 47 CFR § 25.213, and instead appears to leave this sentence incomplete: “Meet the requirements contained to protect radio astronomy service (RAS) observations in the 1610.6-1613.8 MHz band from harmful interference;” We recommend that this be modified to “Meet the requirements contained in Section 100.244(a) to protect …”
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We also share CORF’s concern that the proposed Part 100 rules fail to include the current 47 CFR § 25.228(j)(3) and (j)(4), which are echoed in Footnote US133 to the U.S. Table of Frequency Allocations (47 CFR § 2.106). These rules relate to the operation of Earth stations in motion (ESIMs) in the 14.47-14.5 GHz frequency band in the vicinity of, or within radio line of sight of, RAS observatories observing in the same band. Footnote US342 to the U.S. Table of Frequency Allocations and Footnote 5.149 to the International Table of Frequency Allocations (ITU-R RR Article 5 Section IV) list this band as one in which “administrations are urged to take all practicable steps to protect the radio astronomy service from harmful interference.” We therefore urge the FCC to incorporate the current 47 CFR § 25.228(j)(3) and (j)(4) into the proposed Part 100 rules.
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We support the suggestion from NRAO that blanket licensing not be allowed when applicants are seeking waivers of power levels, beam patterns, or the frequency allocation tables. Given the significance of these waivers, such blanket licensing could open up a range of harmful outcomes in the absence of adequate a priori analysis and understanding.
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We share the concern expressed by NRAO that coordination for Earth station licensing is only discussed in terms of “industry” coordination, rather than including passive spectrum users, such as the RAS. We endorse NRAO’s recommendation that fast-track operation during the public notice period not be allowed when waivers are requested. Similarly, the “Commercial Coordination Conditional Grant” also appears to neglect passive spectrum users, and only discusses coordination with “other commercial operators.” We urge the commission to require coordination with radio astronomy observatories and other passive spectrum users.
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We urge the FCC to continue and codify the practice of requiring satellite constellation operators to execute coordination agreements with the National Science Foundation. Such coordination agreements are critical to ensuring that federal investments in astronomical facilities are not compromised by light pollution and radio frequency interference from satellites. This practice has also provided an extremely useful framework for collaboration between scientists and industry to develop novel mitigation techniques, such as Operational Data Sharing and boresight avoidance.5
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Finally, we reiterate our concern that the proposed shortening of public comment periods would make it increasingly difficult, if not impossible, for smaller stakeholder organizations (without staff dedicated to addressing FCC actions) to provide input on matters of critical long-term importance for the nation.
On behalf of the American Astronomical Society (AAS), thank you for your consideration of the above comments.
Dara Norman, PhD
President, American Astronomical Society
1 The American Astronomical Society webpage: https://aas.org/
2 Comments of the National Academy of Sciences’ Committee on Radio Frequencies: https://www.fcc.gov/ecfs/document/1012097806006/1
3 https://www.reflectorbital.com/
4 https://starlink.com/public-files/Telescope_Boresight_Avoidance.pdf
5 Comments of the National Radio Astronomy Observatory and Green Bank Observatory: https://www.fcc.gov/ecfs/document/10107121649318/1